Title
Heirs of Latayan vs. Tan
Case
G.R. No. 201652
Decision Date
Dec 2, 2015
Simeon contested CARP coverage of his land, claiming exemption and lack of due process. Courts ruled DAR Secretary, not DARAB, had jurisdiction over administrative CARP issues, dismissing the case without prejudice.
validity of cancellation
exclusive jurisdiction
jurisdiction
A

Case Summary (G.R. No. 201652)

Factual Background

Petitioners’ predecessor-in-interest, Simeon Latayan, alleged ownership of two adjoining lots covered by Transfer Certificates of Title Nos. T-14201 and T-14202 totaling 23.1488 hectares. Simeon averred that his titles were cancelled and the lands were compulsorily covered under the Comprehensive Agrarian Reform Program (CARP) without his consent, notice, or payment of just compensation, and were thereafter divided and distributed to respondents through CLOAs Nos. CL-3731 and CL-3729. He asserted that the properties were fully developed agro-industrial estate leased to Southern Tropical Fruits, Incorporated (STFI), were within the one-thousand-meter highway strip under PD 399, and thus were excluded from CARP; and that respondents were not occupant farmers nor did they introduce improvements. Simeon prayed for cancellation of the CLOAs, restoration of his titles, and a preliminary mandatory injunction to preserve the status quo.

PARAD Ruling

The PARAD rendered judgment for Simeon on July 10, 2000, holding that he received no notice of coverage and was denied due process in the administrative steps for CARP implementation; it declared the compulsory coverage and the CLOAs null and void and ordered re-documentation and proper coverage anew. The PARAD’s denial of respondents’ motion for reconsideration was embodied in its September 13, 2000 Resolution.

Proceedings before the DARAB

Respondents appealed to the DARAB. While the appeal was pending Simeon died and was substituted by petitioners. On May 9, 2005 the DARAB set aside the PARAD Decision and dismissed the case for lack of jurisdiction, reasoning that the controversies concerned classification and identification of landholdings and the identification of farmer-beneficiaries, matters falling within the exclusive jurisdiction of the DAR Secretary under DAR Administrative Order No. 6, Series of 2000 and administrative law implementing CARP. Petitioners’ motion for reconsideration was denied by DARAB on January 6, 2009.

Court of Appeals Proceedings

Petitioners sought review in the Court of Appeals. In its April 29, 2011 Decision the CA affirmed the DARAB but modified aspects of its reasoning. The CA concluded that although the case originated as an action for cancellation of CLOAs and might appear cognizable by the PARAD and DARAB, the substance of the controversy involved administrative implementation of agrarian reform — classification and identification of landholdings for coverage and the qualification of identified beneficiaries — which are Agrarian Law Implementation (ALI) cases within the primary jurisdiction of the DAR Secretary. The CA therefore held that DARAB lacked subject-matter jurisdiction and dismissed the case without prejudice, allowing refiling before the DAR Secretary.

Issues Presented on Review

The dispositive issue brought to the Supreme Court was whether the CA erred in ruling that the DAR Secretary, and not the DARAB, had jurisdiction to resolve the controversy involving cancellation of CLOAs and related claims of lack of notice and denial of just compensation, in light of petitioners’ invocation of Section 50 of RA 6657, Sections 1 and 2, Rule II of the 1994 DARAB Rules of Procedure, and controlling jurisprudence purportedly vesting exclusive original jurisdiction in the DARAB over such matters.

Petitioners’ Contentions

Petitioners argued that the CA misapplied the law by awarding primary jurisdiction to the DAR Secretary because Section 50 of RA 6657, Sections 1 and 2, Rule II of the 1994 DARAB Rules of Procedure, and settled jurisprudence vested exclusive original jurisdiction in the DARAB to hear cancellation of CLOAs, determination of just compensation, and similar disputes. They contended that administrative issuances such as AO 06-00 could not supersede statutory grant of jurisdiction, that the CLOAs had already been registered thus placing the case beyond the scope of AO 06-00, and that the resolution of just compensation is a judicial function reserved to adjudicatory bodies.

Respondents’ Contentions

Respondents maintained that the controversy primarily concerned the validity of CARP coverage and the qualification of the purported farmer-beneficiaries, which are ALI matters falling within the DAR Secretary’s exclusive and primary jurisdiction pursuant to AO 06-00, Sections 49 and 50 of the CARP, and the 1994 DARAB Rules. They argued that jurisdiction can be raised at any stage, that the DARAB and the CA correctly recognized that the dispute lacked tenurial relationships necessary to render it an agrarian dispute cognizable by the DARAB, and that precedent such as Heirs of Julian Dela Cruz v. Heirs of Alberto Cruz supported the DAR Secretary’s jurisdiction over non-tenurial CLOA cancellations.

The Supreme Court’s Ruling

The Supreme Court denied the petition and affirmed the Court of Appeals’ dismissal of DARAB Case No. XI-1589-DC-99 for lack of jurisdiction. The Court modified the CA’s judgment by deleting the qualification that petitioners’ re-filing must be in accordance with DAR AO 06-00 within thirty days. The Court held that jurisdiction is a question of law determined from the complaint’s material allegations, the nature of the issues, and the relief sought, and that where those issues implicate matters within the exclusive competence of a specialized administrative agency, such as the Office of the DAR Secretary for ALI cases, the agency has primary jurisdiction to resolve them.

Legal Basis and Reasoning

The Court examined the Amended Complaint and identified that petitioners’ claims centered on lack of notice of coverage, absence of express consent to the fixing of just compensation, nonqualification of respondents as farmers-beneficiaries, the alleged agro-industrial nature and PD 399 exclusion of the lands, and alleged abuse by PARO, MARO, Regional Director and Register of Deeds in applying CARP to the entire area. The Court recited Section 1, Rule II of the 1994 DARAB Rules of Procedure, which conferred primary and exclusive jurisdiction on the DARAB for agrarian disputes but reserved matters involving strictly the administrative implementation of CARP to the DAR Secretary. The Court applied the doctrine that for the DARAB to acquire jurisdiction the controversy must rel

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