The Supreme Court has affirmed that the Department of Agrarian Reform (DAR) Secretary holds exclusive original jurisdiction over cases involving the cancellation of registered emancipation patents, certificates of land ownership award, and other titles issued under any agrarian reform program. This ruling clarifies the jurisdictional boundaries between the DARAB and the DAR Secretary, ensuring that cases requiring specialized agrarian expertise are handled by the appropriate administrative body. This decision impacts landowners and agrarian reform beneficiaries, guiding them to the correct forum for resolving disputes related to land titles issued under agrarian reform programs.

Land Rights in Dispute: When Does the DAR Secretary Have the Final Say?

This case arose from a dispute over a nine-hectare portion of agricultural riceland in Tarlac. Petitioners, claiming prior possession and rights, sought to cancel the emancipation patents and titles issued to respondents, alleging fraud. The central legal question was whether the Department of Agrarian Reform Adjudication Board (DARAB) or the DAR Secretary had jurisdiction over the cancellation of these titles, especially considering the passage of Republic Act (RA) 9700, which amended the Comprehensive Agrarian Reform Law.

The petitioners argued that they, not the respondents, were the rightful beneficiaries of the land, having been in possession of it since 1978 through their predecessors-in-interest. They claimed to have filed applications with the Municipal Agrarian Reform Office (MARO), which were allegedly lost, and that the respondents fraudulently secured the emancipation patents. The respondents countered that the MARO and the DAR had duly identified them as qualified farmer-beneficiaries, leading to the issuance of the patents and titles in their favor. The Provincial Agrarian Reform Adjudicator (PARAD) initially dismissed the complaint, upholding the validity of the respondents’ titles based on the presumption of regularity in the DAR’s administrative processes.

The DARAB initially affirmed the PARAD’s decision but later divested itself of jurisdiction, citing RA 9700, which transferred jurisdiction over cancellation cases to the DAR Secretary. The Court of Appeals (CA) upheld this decision, emphasizing that RA 9700 was already in effect when the appeal was filed with the DARAB. The Supreme Court, in its review, affirmed the CA’s ruling, underscoring the importance of adhering to the statutory allocation of jurisdiction.

At the heart of the matter is Section 9 of RA 9700, which amended Section 24 of RA 6657, stating:

SEC. 24. Award to Beneficiaries. — x x x x

x x x x

All cases involving the cancellation of registered emancipation patents, certificates of land ownership award, and other titles issued under any agrarian reform program are within the exclusive and original jurisdiction of the Secretary of the DAR.

This provision clearly vests the DAR Secretary with the authority to resolve cases involving the cancellation of agrarian reform titles, irrespective of whether they are registered with the Land Registration Authority (LRA). The Supreme Court emphasized that the CA correctly applied this provision in affirming the DARAB’s divestment of jurisdiction. The court also noted that the DARAB lacked jurisdiction to take cognizance of the appeal, as RA 9700 was already in effect when the petitioners filed their appeal.

The Supreme Court highlighted that a petition for review on certiorari under Rule 45 of the Rules of Court is limited to reviewing errors of law, not factual findings. In this case, the petitioners were essentially asking the Court to re-evaluate evidence to determine who possessed the land, which falls outside the Court’s purview in a Rule 45 petition. While exceptions exist for reviewing factual findings, none applied in this instance.

Moreover, the doctrine of primary jurisdiction dictates that cases requiring the expertise of administrative bodies should first be addressed in administrative proceedings before judicial intervention. In this case, the Supreme Court noted:

[I]f a case is such that its determination requires the expertise, specialized training and knowledge of the proper administrative bodies, relief must first be obtained in an administrative proceeding before a remedy is supplied by the courts even if the matter may well be within their proper jurisdiction.

The enactment of RA 9700 meant that the petitioners should have directed their appeal or filed a new case with the DAR Secretary, the administrative body with the necessary expertise to resolve the issue. Their premature appeal to the CA and the Supreme Court was therefore deemed fatal to their cause of action.

In summary, the Supreme Court underscored the importance of respecting the administrative process and the specialized jurisdiction of the DAR Secretary in agrarian reform matters. The decision reinforces the principle that administrative remedies must be exhausted before judicial intervention, particularly in cases involving complex issues requiring administrative expertise. This ruling provides clarity and guidance for landowners, agrarian reform beneficiaries, and legal practitioners navigating disputes related to land titles issued under agrarian reform programs.

FAQs

What was the key issue in this case?	The key issue was determining which body, the DARAB or the DAR Secretary, has jurisdiction over cases involving the cancellation of emancipation patents and titles issued under agrarian reform programs.
What is an emancipation patent?	An emancipation patent is a title issued to qualified farmer-beneficiaries under the Comprehensive Agrarian Reform Program (CARP), granting them ownership of the land they cultivate.
What is RA 9700?	RA 9700 is Republic Act No. 9700, which amended RA 6657 (the Comprehensive Agrarian Reform Law), and transferred the exclusive original jurisdiction over cases involving the cancellation of agrarian reform titles to the DAR Secretary.
What does the doctrine of primary jurisdiction mean?	The doctrine of primary jurisdiction means that if a case requires the expertise of an administrative body, the courts should defer to that body’s specialized knowledge and allow it to resolve the issue first.
Who are the petitioners in this case?	The petitioners are Adriano S. Lorenzo, Sr., Jose D. Flores III, and Carlos S. Flores, who claimed prior possession and rights over the land in question.
Who are the respondents in this case?	The respondents are Dominador M. Libunao, Evagrio S. Libunao, Noe S. Libunao, and Mayo S. Libunao, who were issued emancipation patents and titles to the land.
What was the Court of Appeals’ decision?	The Court of Appeals denied the petition for review, affirming that the DARAB lacked jurisdiction to resolve the appeal due to RA 9700.
What was the Supreme Court’s ruling?	The Supreme Court affirmed the Court of Appeals’ decision, holding that the DAR Secretary has exclusive original jurisdiction over cases involving the cancellation of registered emancipation patents and titles issued under agrarian reform programs.
What should petitioners have done in this case?	Petitioners should have directed their appeal or filed a new case for cancellation of respondents’ patents and titles before the DAR Secretary instead of appealing to the CA and the Supreme Court.

In conclusion, the Supreme Court’s decision reinforces the jurisdictional boundaries between the DARAB and the DAR Secretary, emphasizing the importance of adhering to statutory provisions and administrative processes in agrarian reform disputes. This ruling clarifies that the DAR Secretary is the proper forum for resolving cases involving the cancellation of agrarian reform titles, ensuring that such cases are handled by the administrative body with the requisite expertise and knowledge.

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: Adriano S. Lorenzo, Sr., et al. v. Dominador M. Libunao, et al., G.R. No. 261059, February 15, 2023