The Supreme Court clarified that the Department of Agrarian Reform Adjudication Board (DARAB) possesses jurisdiction over cases involving the annulment of deeds of sale and the cancellation of titles related to agricultural lands, even if no direct agrarian dispute exists. This jurisdiction extends to instances where land sales appear to circumvent agrarian reform laws, specifically those limiting land ownership. This ruling ensures that the DARAB can address transactions that undermine the Comprehensive Agrarian Reform Program (CARP), safeguarding the rights of potential agrarian reform beneficiaries and upholding the integrity of land reform initiatives.

Land Transfers Under Scrutiny: Can DARAB Nullify Sales Violating Agrarian Reform?

The case revolves around properties in Laguna originally owned by Eduardo Reyes. In 1997, Reyes sold these lands to Igmidio D. Robles, Randy V. Robles, Mary Krist B. Malimban, Anne Jamaica G. Robles, John Carlo S. Robles, and Christine Anne V. Robles. In 2006, the Department of Agrarian Reform (DAR) sought to annul these sales, arguing that Reyes failed to secure prior DAR clearance as mandated by the Comprehensive Agrarian Reform Law (CARL) and its implementing rules. The DARAB initially denied a motion to dismiss, but the Court of Appeals (CA) reversed this decision, stating that the DARAB lacked jurisdiction over the case, as it did not involve an existing agrarian dispute or tenurial relationship. The Supreme Court then had to determine whether the DARAB’s jurisdiction extended to cases involving the annulment of land sales and title cancellations where violations of agrarian reform laws were alleged, irrespective of the presence of a traditional agrarian dispute.

In its analysis, the Supreme Court emphasized the principle that jurisdiction is determined by the allegations in the complaint and the nature of the relief sought. The Court quoted Heirs of Julian dela Cruz v. Heirs of Alberto Cruz, stating:

It is axiomatic that the jurisdiction of a tribunal, including a quasi-judicial officer or government agency, over the nature and subject matter of a petition or complaint is determined by the material allegations therein and the character of the relief prayed for, irrespective of whether the petitioner or complainant is entitled to any or all such reliefs.

Building on this principle, the Court acknowledged the two-fold jurisdiction of the DAR: executive and quasi-judicial. The executive function pertains to the enforcement and administration of agrarian laws, while the quasi-judicial function involves determining the rights and obligations of parties involved in agrarian disputes. The Court clarified that while the DARAB’s jurisdiction is generally limited to agrarian disputes involving tenancy relationships, it also extends to other “agrarian reform matters” not exclusively under the jurisdiction of the Secretary of DAR, the Department of Agriculture, the Department of Environment and Natural Resources, or the Special Agrarian Courts.

The Court then referenced DAR Memorandum Circular (M.C.) No. 02-01, which provides guidelines on the annulment of conveyances violating Section 6, paragraph 4 of R.A. No. 6657. This circular authorized the filing of petitions for annulment before the Provincial Agrarian Reform Adjudicator (PARAD) on behalf of the PARO. The Court noted that while the subject properties were not under the administration of the DAR or LBP (i.e., not yet acquired for CARP purposes), the petition alleged that the lands were agricultural and that their sale exceeded the retention limits set by the CARL. This raised concerns about potential circumvention of agrarian reform laws.

In examining the scope of the CARL, the Court cited Sarne v. Hon. Maquiling, construing the phrase “agricultural lands under the coverage of the CARP” to include all private lands devoted to or suitable for agriculture, as defined in Section 4 of R.A. No. 6657. Therefore, a notice of coverage is not necessarily required for the DARAB to exercise jurisdiction over cases involving the sale or alienation of agricultural lands falling under CARP coverage. Section 4 of RA 6657 states:

Section 4. Scope. — The Comprehensive Agrarian Reform Law of 1989 shall cover, regardless of tenurial arrangement and commodity produced, all public and private agricultural lands, as provided in Proclamation No. 131 and Executive Order No. 229, including other lands of the public domain suitable for agriculture.

More specifically the following lands are covered by the Comprehensive Agrarian Reform Program:
(a) All alienable and disposable lands of the public domain devoted to or suitable for agriculture.
(b) All lands of the public domain in excess of the specific limits as determined by Congress in the preceding paragraph;
(c) All other lands owned by the Government devoted to or suitable for agriculture; and
(d) All private lands devoted to or suitable for agriculture regardless of the agricultural products raised or that can be raised thereon.

The Court further addressed the issue of the notices of coverage being issued to the heirs of Eduardo Reyes, the former owner, instead of the respondents, the current owners. The Court acknowledged that the DAR’s mistake was understandable, given that the deeds of sale were registered only in 2005, after Reyes’s death. However, the Court also pointed out that the land areas sold to the respondents were within the 5-hectare retention limit, making the issuance of notices of coverage less critical in this particular case. Furthermore, the Court highlighted the existence of Deeds of Surrender of Tenancy Rights and certifications from local officials, casting doubt on the validity of the land transfer and raising suspicions of an attempt to circumvent the retention limits and CARP coverage.

This approach contrasts with the ruling in Department of Agrarian Reform v. Paramount Holdings Equities, Inc., where the Court found that the DARAB lacked jurisdiction because the petition failed to allege any tenurial or agrarian relations and the lands had not been subject to a notice of coverage. The Court distinguished the present case from Paramount, noting that here, the DAR’s petition alleged a notice of coverage and that the sales potentially violated Section 6, paragraph 4 of R.A. No. 6657, relating to clearances for the sale and transfer of agricultural lands. The Court emphasized that the DARAB has jurisdiction over agrarian reform matters referred to it by the Secretary of DAR, as outlined in the DARAB Rules of Procedure.

Addressing the respondents’ argument that the lack of annotations on the titles exempts the properties from CARP coverage, the Court stated that the retention limits under Section 6 of RA 6657 constitute statutory liens on the titles, even without explicit annotations. This imputes knowledge to the respondents that the transfer of properties exceeding the retention limit could be illegal. Finally, the Court dismissed the respondents’ claim that the titles had become incontrovertible and indefeasible, clarifying that this principle does not prevent challenges to the legality of the transfer of title due to violations of agrarian laws. The Supreme Court then concluded that the DARAB possessed jurisdiction over the case and reversed the Court of Appeals’ decision.

FAQs

What was the key issue in this case?	The central question was whether the DARAB has jurisdiction to annul deeds of sale and cancel titles of agricultural lands when the sales allegedly violate agrarian reform laws, even without a direct agrarian dispute involving tenants.
What did the Court decide?	The Supreme Court ruled that the DARAB does have jurisdiction in such cases, particularly when the sales appear to circumvent the Comprehensive Agrarian Reform Program (CARP) and its land ownership limits.
What is the Comprehensive Agrarian Reform Program (CARP)?	CARP is a government initiative aimed at redistributing agricultural lands to landless farmers and farmworkers, promoting social justice, and increasing agricultural productivity. It sets limits on land ownership and provides mechanisms for land acquisition and distribution.
What is a ‘notice of coverage’ and is it always required?	A notice of coverage informs a landowner that their land is subject to CARP. The court clarified that while important, it is not always essential for DARAB jurisdiction, especially if sales of agricultural lands are involved.
What are ‘retention limits’ under CARP?	Retention limits refer to the maximum area of agricultural land a landowner can retain after CARP implementation, typically five hectares. Sales exceeding these limits are subject to scrutiny to prevent circumvention of agrarian reform.
What does it mean to ‘circumvent’ CARP?	Circumvention refers to actions taken by landowners to avoid CARP coverage or its limitations, such as transferring land to relatives or other parties to exceed retention limits. Such actions are often deemed illegal.
Are titles to land automatically protected after one year?	While titles generally become incontrovertible after one year, this protection does not apply if the transfer of title was illegal due to violations of agrarian laws. The legality of the transfer can still be challenged.
What is the role of DAR Memorandum Circulars in this case?	DAR Memorandum Circulars provide guidelines for implementing agrarian reform laws. DAR M.C. No. 02-01 specifically addresses the annulment of land conveyances violating Section 6, paragraph 4 of R.A. No. 6657.

In conclusion, the Supreme Court’s decision reinforces the DARAB’s authority to address land transactions that potentially undermine agrarian reform. This ruling empowers the DARAB to investigate and nullify sales designed to evade CARP’s land ownership limits, safeguarding the program’s objectives and ensuring equitable land distribution.

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: DEPARTMENT OF AGRARIAN REFORM vs. ROBLES, G.R. No. 190482, December 09, 2015