Case Summary (G.R. No. 176838)
Antecedents of the Case
The case began when DAR, through Provincial Agrarian Reform Officer Felixberto Q. Kagahastian, filed a petition to nullify sales of several parcels of land made to the respondents. The claim centered on the assertion that these lands were agricultural and that the sale occurred without the necessary clearance from the DAR, as required by the Comprehensive Agrarian Reform Law (Republic Act No. 6657). The DAR learned of the transactions after being directed to investigate by the Secretary of Agrarian Reform, following a request from individuals claiming to be tenant-farmers of the said properties.
Respondent's Defense
The respondents contended that the DARAB lacked jurisdiction over the matter, asserting that the case involved administrative implementation of R.A. No. 6657 and should have been cognizable solely by the Secretary of Agrarian Reform. They also raised issues such as prescription, litis pendens, res judicata, and forum shopping in their petition for dismissal.
Ruling of the Provincial Adjudicator
On October 16, 2002, Provincial Adjudicator Virgilio M. Sorita dismissed the petition, reasoning that the DARAB's jurisdiction covered only those sales involving agricultural lands already under the Comprehensive Agrarian Reform Program (CARP) or similar agrarian laws. He maintained that the case pertained to the sale of private lands, not agricultural lands administered by the DAR. Additionally, he pointed out that the petition failed to show that it was filed with the Solicitor General's backing.
Ruling of the DARAB
The DARAB later reversed PA Sorita's decision in its ruling dated August 18, 2004. It concluded that the lack of necessary clearance indicated fraudulent transactions and ruled that the Provincial Agrarian Reform Officer (PARO) had the authority to file the petition even without the Solicitor General's involvement. The DARAB asserted jurisdiction over the case based on its authority to handle cancellations of deeds of sale concerning agricultural lands.
Ruling of the Court of Appeals
The Court of Appeals decided on October 12, 2006, to annul the DARAB's decision. It reasoned that the case fundamentally involved the nullification of a sale, which did not constitute an agrarian dispute under the DARAB's jurisdiction. The Court highlighted that the case's allegations did not pertain to entrenched agrarian relations among the parties involved.
Issues Raised in the Present Petition
In the current petition, DAR sought a resolution regarding the jurisdiction of the DARAB over the petition for nullification of the sale of the properties. The issues raised included the procedural adherence of DAR in filing the petition, specifically regarding service of the petition, necessary supervening documents, and the authority of the Solicitor General.
Supreme Court's Ruling
The Supreme Court affirmed the Court of Appeals' ruling, emphasizing that
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Background of the Case
- The case arises from a Petition for Review filed by the Department of Agrarian Reform (DAR) against the Court of Appeals (CA) Decision dated October 12, 2006, and Resolution dated January 10, 2007.
- The CA granted the appeal of respondents Paramount Holdings Equities, Inc. and others, reversing the Department of Agrarian Reform Adjudication Board (DARAB) ruling in DARAB Case No. 12284.
- The underlying issue involves the sale of several parcels of land without the required clearance from the DAR, as stipulated by the Comprehensive Agrarian Reform Law (CARL).
Antecedents of the Case
- The DAR, through Provincial Agrarian Reform Officer (PARO) Felixberto Q. Kagahastian, filed a petition (DARAB Case No. R 0403-0009-02) to nullify the sale of lands to the respondents.
- The details of the contested sales include several titles and their respective areas, all involving transactions with the Golden Mountain Agricultural Development Corporation and Green Mountain Agricultural Development Corporation.
- The PARO contended that these properties were agricultural lands and that the sale was void due to the absence of DAR Clearance.
Jurisdictional Challenges
- Respondents contended the matter should be cognizable by the Secretary of Agrarian Reform, not the DARAB, citing issues of prescription, litis pendentia, res judicata, and forum shopping.
- The Provincial Adjudicator (PA) Sorita dismissed the petition for lack of jurisdiction, stating the DARAB's jurisdiction is confined to lands placed under agrarian reform laws and do