The Supreme Court ruled that while the Department of Agrarian Reform Adjudication Board (DARAB) has the power to adjudicate agrarian disputes, it cannot overrule the Department of Agrarian Reform’s (DAR) administrative decisions on who qualifies as an agrarian reform beneficiary. The DAR’s expertise in identifying and selecting beneficiaries is primary, and the DARAB must generally defer to these findings. The DARAB’s authority is limited to ensuring the applicant’s membership in a recognized farmers’ cooperative and compliance with land compensation requirements, not reassessing the DAR’s beneficiary qualifications.

From Tenant to Engineer: Can DARAB Override DAR’s Beneficiary Decisions?

This case arose from a dispute over land in Nueva Ecija, initially part of the Cojuangco estate and placed under Operation Land Transfer. Pedro Tejada was awarded a portion of this land but later allegedly surrendered it. Sonny Manuel, the petitioner, sought to have the emancipation patent issued in Tejada’s name canceled and a new one issued in his favor. The DARAB affirmed the cancellation of Tejada’s patent but denied Manuel’s application, finding him ineligible because he was a government engineer and not an actual tiller of the land. This decision raised a critical question: Can the DARAB, in resolving an application for an emancipation patent, question the DAR’s determination of an applicant’s status as an agrarian reform beneficiary?

The Supreme Court addressed the scope of authority between the DAR and the DARAB. The Court emphasized that Republic Act No. 6657 (Comprehensive Agrarian Reform Law) vests the DAR with primary jurisdiction to determine and adjudicate agrarian reform matters. Specifically, the DAR has the exclusive original jurisdiction over all matters involving the implementation of agrarian reform, except those falling under the exclusive jurisdiction of the Department of Agriculture (DA) and the Department of Environment and Natural Resources (DENR). Previously, Executive Order (E.O.) No. 129-A created the DARAB to exercise quasi-judicial powers.

The Court cited Section 50 of R.A. No. 6657, stating:

Section 50. Quasi-Judicial Powers of the DAR. – The DAR is hereby vested with primary jurisdiction to determine and adjudicate agrarian reform matters and shall have exclusive original jurisdiction over all matters involving the implementation of agrarian reform, except those falling under the exclusive jurisdiction of the Department of Agriculture (DA) and the Department of Environment and Natural Resources (DENR).

Inherent in DAR’s power is its authority to identify qualified agrarian reform beneficiaries. This includes selecting a substitute beneficiary when the original one surrenders or abandons their claim. The DAR must adhere to specific procedures, including the waiver being made in favor of the government, recommendation of qualified beneficiaries by the Samahang Nayon (SN), and a formal order declaring the disqualification of the abandoning beneficiary. The Court emphasized that the DAR’s administrative prerogative in identifying and selecting beneficiaries should be respected by the courts, and equally, the DARAB, absent grave abuse of discretion.

The Supreme Court has previously held that the identification and selection of CARP beneficiaries are matters involving strictly the administrative implementation of the CARP. As such, it is incumbent upon the courts to exercise great caution in substituting their own determination of the issue, unless there is grave abuse of discretion committed by the administrative agency. The DARAB cannot review, much less reverse, the administrative findings of the DAR. Instead, the DARAB should defer to the DAR’s expertise in identifying and selecting beneficiaries.

According to the Court, the quasi-judicial powers of the DARAB, as defined in its rules, are limited. Specifically, the 1994 New Rules of Procedure state:

Section 1. Primary and Exclusive Original and Appellate Jurisdiction -The Board shall have primary and exclusive jurisdiction, both original and appellate, to determine and adjudicate all agrarian disputes involving the implementation of the Comprehensive Agrarian Reform Program (CARP) under Republic Act No. 6657, Executive Order Nos. 228 and 129-A, Republic Act No. 3844 as amended by Republic Act No. 6389, Presidential Decree No. 27 and other agrarian laws and their implementing rules and regulations. Specifically, such jurisdiction shall include but not be limited to cases involving the following:

x x x x

f) Those involving the issuance, correction and cancellation of Certificates of Land Ownership Award (CLOAs) and Emancipation Patents (EPs) which are registered with the Land Registration Authority;

g) Those cases previously falling under the original and exclusive jurisdiction of the defunct Court of Agrarian Relations under Section 12 of Presidential Decree No. 946, except sub-paragraph (q) thereof and Presidential Decree No. 815.

In cases involving the issuance of emancipation patents to substitute beneficiaries, the DARAB’s authority is confined to verifying the applicant’s membership in a recognized farmers’ cooperative and ensuring compliance with land compensation requirements. It cannot reassess the DAR’s determination of the applicant’s qualifications as an agrarian reform beneficiary. However, in cases involving the cancellation of a registered emancipation patent, the DARAB can inquire into the qualifications of the patent holder to determine if they misrepresented their basic qualifications.

In this case, the Supreme Court found that the DARAB and the Court of Appeals exceeded their authority by reversing the DAR’s finding on Manuel’s qualifications. Because the proceeding involved an application for the issuance of an emancipation patent, the DARAB should have limited its adjudication to whether Manuel had been appointed a substitute beneficiary by the DAR, whether he was a member of the SN, and whether he had fully paid the just compensation amount. Manuel presented evidence supporting his status as an identified agrarian reform beneficiary, including the MARO’s Report and Recommendation and SN Resolution No. 12.

Moreover, the Court found the DARAB’s finding of abandonment to be purely speculative. According to MC No. 4, abandonment is defined as:

Farm lots shall be considered abandoned under any of the following grounds:

1. Failure to cultivate the lot due to reasons other than the non-suitability of the land to agricultural purposes, for at least two (2) calendar years and to pay the amortizations for the same period.
2. Permanent transfer of residence by the beneficiary and his family which has rendered him incapable of cultivating the lot.
3. Relinquishment of possession of the lot for at least two (2) calendar years and to pay amortization for the same period.

Employment or transfer of residence alone does not constitute abandonment unless coupled with a failure to cultivate the land. The DARAB and the Court of Appeals failed to provide evidence that Manuel and his family had stopped cultivating the land.

FAQs

What was the key issue in this case?	The central issue was whether the DARAB could overrule the DAR’s determination of an applicant’s qualifications as an agrarian reform beneficiary in a proceeding for the issuance of an emancipation patent.
What is the DAR’s primary role in agrarian reform?	The DAR is primarily responsible for the implementation of agrarian reform laws, including the identification and selection of qualified agrarian reform beneficiaries.
What are the limitations on DARAB’s authority?	The DARAB cannot review or reverse the administrative findings of the DAR. Its authority is limited to specific aspects of agrarian disputes, such as the issuance, correction, and cancellation of CLOAs and EPs.
What constitutes abandonment of agrarian land?	Abandonment requires a failure to cultivate the land for at least two calendar years, a permanent transfer of residence rendering cultivation impossible, or relinquishment of possession for at least two years.
What evidence did Manuel present to support his claim?	Manuel presented the MARO’s Report and Recommendation, SN Resolution No. 12, and evidence of amortization payments to demonstrate his status as an agrarian reform beneficiary.
What is the significance of MC No. 4?	MC No. 4 outlines the procedures for transferring land covered by P.D. No. 27 due to abandonment, waiver of rights, or illegal transactions.
What factors are considered in determining if an agrarian reform beneficiary has abandoned the land?	The factors include failure to cultivate, permanent transfer of residence making cultivation impossible, and relinquishment of possession, each for at least two years.
What is the role of the Samahang Nayon (SN)?	The Samahang Nayon plays a role in recommending qualified beneficiaries when a previous beneficiary surrenders their claim.
Can the DARAB inquire into the qualifications of an emancipation patent holder?	Yes, but only in proceedings for the cancellation of a registered emancipation patent, to determine if the holder misrepresented their basic qualifications.

The Supreme Court’s decision reinforces the DAR’s administrative authority in identifying agrarian reform beneficiaries, preventing the DARAB from undermining the agency’s expertise. This ensures the efficient and effective implementation of agrarian reform laws, upholding the rights of qualified beneficiaries.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: SONNY B. MANUEL vs. DARAB and PEDRO TEJADA, G.R. NO. 149095, July 24, 2007