Case Summary (Adm. Case No. 8108, 10299)
Applicable Law
The underlying legal framework guiding this case is anchored on the Comprehensive Agrarian Reform Law (R.A. No. 6657) of 1988, along with relevant administrative issuances and prior administrative decisions that delineate the jurisdiction of various bodies within the Department of Agrarian Reform (DAR) concerning the selection and identification of eligible beneficiaries under CARP.
Initiation of the Agrarian Dispute
The land in question was seized under the Compulsory Acquisition Scheme of CARP, following a Notice of Coverage sent to landowners on June 16, 1993, which identified potential beneficiaries, including both petitioners and respondents. The determination of beneficiaries soon became contentious, with respondents filing a complaint in March 1995 asserting their rights as tenants and beneficiaries while disputing the eligibility of petitioners based on their claims of voluntary relinquishment.
Administrative Proceedings and Decisions
The dispute saw movements through various administrative bodies, beginning with the Provincial Adjudicator (PARAD), which initially dismissed the respondents' claims on grounds that they had waived their rights as tenants. However, upon appeal, the Department of Agrarian Reform Adjudication Board (DARAB) contradicted PARAD’s decision and ordered the cancellation of petitioner-issued Certificates of Land Ownership Award (CLOAs), asserting that voluntary surrender from beneficiaries must be corroborated by evidence establishing advantageous conditions for such relinquishment.
Court of Appeals Rulings
The case reached the Court of Appeals, which, in its early rulings, found in favor of the petitioners, only to later reverse its decision upon reconsideration, reinstating DARAB’s findings. The CA emphasized the significance of the initial tenurial relationships and contractual agreements that established the respondents’ purported claims as tenants over the land.
Jurisdictional Issues
Central to the findings was the question of jurisdiction concerning the DARAB and its ability to decide on matters relating to the identification of CARP beneficiaries. The Supreme Court asserted that the identification and selection of beneficiaries fall under the exclusive jurisdiction of the DAR Secretary, which is a function that cannot be arbitrated by the DARAB. The Court reaffirmed that administrative actions regarding beneficiary selection should remain strictly a prerogative of the DAR.
Supreme Court Findings
The Supreme Court granted the petitioners' request, effectively reversing the Court of Appeals' amended decision that reinstated the DARAB decision. The Court underscored the lack of jurisdiction exercised by DARAB in determining beneficiary eligibility, thereby reinfo
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Case Overview
- The petitioners, Romanita Concha, Benita Cosico, Domingo Garcia, and others, seek to set aside the Amended Decision of the Court of Appeals (CA) in CA-G.R. SP No. 73303.
- The case revolves around the qualification of beneficiaries for a landholding covered by Transfer Certificate of Title Nos. T-140494, T-140492, and T-140491, with a total area of approximately 33.5006 hectares.
- The land was subject to the Compulsory Acquisition Scheme of the Comprehensive Agrarian Reform Program (CARP) initiated by the government.
Background of the Case
- On June 16, 1993, a Notice of Coverage was issued to the landowners.
- An affidavit dated August 17, 1993, by the Municipal Agrarian Reform Officer (MARO) identified several beneficiaries, including members of both the petitioners and respondents.
- On March 24, 1995, the respondents filed a complaint asserting their tenancy rights and qualification as beneficiaries, claiming they had not relinquished their rights.
Key Developments
- The landowners sought to convert the land for development purposes, and the Department of Agrarian Reform (DAR) approved their application with conditions.
- The MARO pursued the coverage of 18.5006 hectares of the land, identifyin