The Supreme Court affirmed the Department of Agrarian Reform Adjudication Board’s (DARAB) jurisdiction over cases involving the redemption of agricultural lands, even if these lands are not under the direct administration of the Department of Agrarian Reform (DAR) or the Land Bank of the Philippines (LBP). This decision reinforces the security of tenure for agricultural tenants by ensuring their right to redeem land sold without their knowledge, as enshrined in the Agricultural Land Reform Code. The ruling clarifies that the DARAB’s authority extends to all disputes concerning agricultural land sales and tenant rights, thereby protecting vulnerable farmers and promoting agrarian justice.

Protecting the Harvest: Tenant Rights vs. Landowner Sales in Zamboanguita

This case originated from a dispute in Zamboanguita, Negros Oriental, where private respondents, claiming to be tenants of a parcel of land owned by petitioner Laura Sarne, sought to redeem the land after Sarne sold it to petitioners Lorenzo, Lowena, Pedro, and Jenelyn Jaugan without their knowledge. The Rafals, as tenants, asserted their right of preemption and redemption under Sections 11 and 12 of Republic Act No. 3844, the Code of Agrarian Reform. They alleged that Sarne had initially offered to sell the land to them but later reneged on the agreement and sold it to the Jaugans instead. This prompted the Rafals to file a complaint with the DARAB, seeking to exercise their right to redeem the property at the originally agreed price.

Sarne and the Jaugans contested the DARAB’s jurisdiction, arguing that the case was essentially one for specific performance, which should be filed with regular courts. They further contended that since the land was not under the administration of the DAR or the LBP, the DARAB lacked the authority to hear the case. The Provincial Adjudicator, however, ruled in favor of the Rafals, asserting jurisdiction over the complaint for redemption and damages. This decision was upheld by the Court of Appeals, leading Sarne and the Jaugans to appeal to the Supreme Court.

At the heart of the legal matter was the interpretation of Section 12 of R.A No. 3844, which explicitly grants agricultural lessees the right to redeem land sold to a third person without their knowledge:

“Sec. 12. Lessee’s Right of Redemption. – In case the landholding is sold to a third person without the knowledge of the agricultural lessee, the latter shall have the right to redeem the same at a reasonable price and consideration. Provided, That the entire landholding sold must be redeemed. Provided, further, That where there are two or more agricultural lessees, each shall be entitled to said right of redemption only to the extent of the area actually cultivated by him. The right of redemption under this section may be exercised within two (2) years from the registration of the sale and shall have priority over any other right of legal redemption.”

The Supreme Court emphasized that the nature of an action and the jurisdiction of the court are determined by the allegations in the complaint and the character of the relief sought. In this case, the Rafals’ complaint clearly pleaded a cause of action for redemption, which falls squarely within the DARAB’s jurisdiction as defined by Section 1 (e), Rule II of the DARAB Rules of Procedure.

Furthermore, the Court underscored the importance of protecting the security of tenure for agricultural tenants. Citing Hidalgo v. Hidalgo, the Court reiterated that the Land Reform Code creates a legal bond between landowners and farmers, granting tenants the right to continue in possession of the land they work, even if the land is sold or transferred to third persons. This right is further strengthened by Section 10 of R.A. No. 3844, which states that the agricultural leasehold relation shall not be extinguished by the sale, alienation, or transfer of the legal possession of the landholding.

The petitioners argued that Romana Rafal had ceased to be a tenant when the subject lot was mortgaged to her, becoming a creditor instead. However, the Court rejected this argument, pointing out that the mortgage of the landholding to the agricultural lessee is not among the causes for termination of the leasehold relationship as specified in Sections 8, 28, and 36 of R.A. No. 3844. Thus, the mortgage did not divest the DARAB of its jurisdiction.

Another key point of contention was the petitioners’ assertion that the DARAB lacked jurisdiction because the land was not under the administration and disposition of the DAR and LBP. The Supreme Court clarified that the DARAB’s jurisdiction, as defined in Section 1, paragraph (e), Rule II of the DARAB New Rules of Procedure, extends to all agrarian disputes involving the sale, alienation, mortgage, foreclosure, preemption, and redemption of agricultural lands under the coverage of the CARP or other agrarian laws, irrespective of whether the land is under the administration of the DAR and LBP.

To further illustrate this point, consider the following table:

Issue	Petitioner’s Argument	Court’s Ruling
Nature of the Case	Specific Performance, not Redemption	Complaint pleaded a cause of action for redemption, within DARAB jurisdiction.
Tenant Status	Romana Rafal ceased to be a tenant upon mortgage	Mortgage to tenant is not a cause for termination of leasehold.
DAR/LBP Administration	DARAB jurisdiction limited to lands under DAR/LBP administration	DARAB jurisdiction extends to all agricultural lands under CARP or other agrarian laws.

The Court emphasized that it should not distinguish where the law does not distinguish. The phrase “agricultural lands under the coverage of the CARP” includes all private lands devoted to or suitable for agriculture, as defined under Section 4 of R.A. No. 6657. The Court noted that the phrase “involving lands under the administration and disposition of the DAR or LBP” appears only in paragraph (c) of Section 1, Rule II, which pertains to cases involving the annulment or cancellation of lease contracts or deeds of sale involving lands. The absence of this proviso in paragraph (e), which is the basis of the Rafals’ cause of action, indicates that it was never intended to be so limited.

FAQs

What was the key issue in this case?	The central issue was whether the DARAB has jurisdiction over cases involving the redemption of agricultural lands not under the direct administration of the DAR or LBP. The Supreme Court affirmed that the DARAB’s jurisdiction extends to all agricultural lands covered by CARP or other agrarian laws.
What is the right of redemption for tenants?	The right of redemption allows tenants to repurchase their tenanted land if it is sold to a third party without their knowledge. This right is enshrined in Section 12 of R.A. No. 3844 and aims to protect tenants from losing their livelihood due to land sales.
Does a mortgage affect a tenant’s rights?	No, the Supreme Court clarified that a mortgage of the landholding to the agricultural lessee does not terminate the leasehold relationship. The tenant’s rights remain protected even if they become a creditor through a mortgage agreement.
What law governs the right of redemption in this case?	The right of redemption is primarily governed by Section 12 of Republic Act No. 3844, also known as the Agricultural Land Reform Code. This law provides the framework for agrarian relations and tenant rights in the Philippines.
What constitutes an agrarian dispute?	An agrarian dispute involves issues related to the rights and obligations of persons engaged in the cultivation and use of agricultural land. This includes disputes over tenancy, leasehold, and the sale or transfer of agricultural land.
Why is security of tenure important for tenants?	Security of tenure ensures that tenants cannot be arbitrarily evicted from the land they cultivate. It is a crucial protection that allows tenants to continue their livelihood and provides stability in their agrarian relationship.
What is the role of the DARAB?	The DARAB is the quasi-judicial body tasked with resolving agrarian disputes in the Philippines. It has primary jurisdiction over matters involving the implementation of agrarian reform laws and the rights of agricultural tenants and landowners.
Can landowners sell agricultural land without informing tenants?	Landowners can sell agricultural land, but they must respect the tenant’s right of preemption, which gives the tenant the first option to buy the land. If the land is sold without the tenant’s knowledge, the tenant has the right to redeem it within a specified period.

In conclusion, the Supreme Court’s decision in this case reaffirms the DARAB’s broad jurisdiction over agrarian disputes and underscores the importance of protecting the rights of agricultural tenants. This ruling provides clarity and reinforces the legal framework that supports agrarian reform and social justice in the Philippines. This case is a reminder of the importance of seeking expert legal counsel when dealing with complex land and agrarian issues.

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: Laura Sarne, et al. vs. Hon. Vivian O. Maquiling, G.R. No. 138839, May 09, 2002