The Supreme Court ruled that the Department of Agrarian Reform (DAR) retains jurisdiction over agrarian reform matters, including land acquisition disputes, even after June 30, 2014, if the proceedings were initiated before this date. This means that landowners involved in agrarian disputes initiated before the deadline cannot bypass the DAR by filing cases in regular courts, as the DAR maintains its authority to resolve these issues. The decision clarifies the scope of DAR’s jurisdiction under Republic Act No. 9700, ensuring the continuation of agrarian reform processes initiated before the specified cut-off date.

When Does Land Reform End? Clarifying DAR’s Authority Over Ongoing Cases

This case, Robustum Agricultural Corporation v. Department of Agrarian Reform and Land Bank of the Philippines, revolves around a petition filed by Robustum Agricultural Corporation (RAC) seeking to remove its land from the coverage of the agrarian reform program. RAC argued that because their petition was filed after June 30, 2014, the DAR no longer had jurisdiction over the matter, suggesting that regular courts should handle the case. The central legal question is whether Section 30 of Republic Act (RA) No. 9700 limits the DAR’s jurisdiction to only those cases pending as of June 30, 2014, or if the DAR retains authority over cases initiated before that date.

The facts of the case are as follows: Robustum Agricultural Corporation owns a 50,000-square meter parcel of agricultural land. This land was part of a larger estate previously owned by Puyas Agro, Inc., RAC’s predecessor. In December 2013, the DAR sent RAC a letter indicating that the larger estate was subject to the agrarian reform program and that RAC, as a transferee, would be included as an alternative landowner and payee for compensation purposes. RAC refused to receive this letter. Subsequently, in June 2014, the DAR published a notice of coverage identifying the estate and RAC’s land as subject to agrarian reform. Consequently, RAC filed a petition for quieting of title and declaratory relief with the Regional Trial Court (RTC), arguing that the notice of coverage was improperly served and unenforceable. The DAR and Land Bank of the Philippines (LBP) countered that the RTC lacked jurisdiction, as the matter pertained to the implementation of the agrarian reform program, which falls under DAR’s exclusive jurisdiction.

The RTC sided with the DAR and LBP, dismissing RAC’s petition for lack of jurisdiction. RAC then appealed directly to the Supreme Court, raising a pure question of law. RAC argued that Section 30 of RA No. 9700 limits DAR’s jurisdiction to cases pending as of June 30, 2014, and that since its petition was filed after this date, the RTC should have jurisdiction. Section 30 of RA No. 9700 states:

SECTION 30. Resolution of Cases. – Any case and/or proceeding involving the implementation of the provisions of Republic Act No. 6657, as amended, which may remain pending on June 30, 2014 shall be allowed to proceed to its finality and be executed even beyond such date.

The Supreme Court disagreed with RAC’s interpretation of Section 30 of RA No. 9700. The Court clarified that this section does not grant jurisdiction to regular courts over agrarian reform matters filed after June 30, 2014. Instead, it authorizes the DAR to continue processing and finalizing cases already pending as of that date. The Court emphasized that a proceeding for compulsory land acquisition and distribution is deemed commenced with the issuance of a notice of coverage. The Court noted that in this case, two notices of coverage had been issued before June 30, 2014: the original notice for the mother estate transmitted in December 2013, and the published notice of June 11, 2014. These notices indicated that a proceeding for compulsory land acquisition was already underway before the cut-off date.

Given this context, the Supreme Court found that RAC’s challenge to the efficacy of the notice of coverage was indeed a matter involving the implementation of agrarian reform. Such a challenge is an integral part of the proceeding for compulsory land acquisition and distribution. Therefore, jurisdiction to resolve this issue, like the main proceeding, rests with the DAR. The authority granted to the DAR under Section 30 of RA No. 9700 includes the power to exercise its quasi-judicial functions under Section 50 of RA No. 6657 regarding any agrarian reform matter arising in such proceedings. The Court stated:

Accordingly, the authority of the DAR to bring to completion a proceeding for land acquisition and distribution initiated prior to June 30, 2014 must be deemed inclusive of a coordinate authority to continue exercising its quasi-judicial powers under Section 50 of RA No. 6657 with respect to agrarian reform controversies that may arise from such proceeding.

To fully understand the implications of Section 30 of RA No. 9700, it is essential to consider the broader context of RA No. 9700 itself. RA No. 9700 is an amendment to RA No. 6657, the Comprehensive Agrarian Reform Law. Enacted in 2009, RA No. 9700 aimed to strengthen and accelerate the agrarian reform program. One of its key provisions was extending the period for land acquisition and distribution. Before RA No. 9700, this period was set to end in 2008. RA No. 9700 extended it by five years, until June 30, 2014. Section 5 of the law amended Section 7 of RA No. 6657 to reflect this extension. The law directed the DAR to complete land acquisition and distribution by June 30, 2014. However, this directive was not absolute. Section 30 of RA No. 9700 qualifies this requirement, allowing cases involving the implementation of the agrarian reform law to proceed beyond that date if they were already pending.

The term “proceeding involving the implementation of the agrarian reform law” is broad enough to encompass the entire process of land acquisition and distribution. This interpretation aligns with the plain meaning of “proceeding,” which refers to any act or step that is part of a larger whole. Therefore, Section 30 of RA No. 9700 clarifies that June 30, 2014, is not an absolute deadline for completing all land acquisition and distribution activities. Instead, it is the final date by which the DAR can initiate such proceedings. Land acquisition and distribution can be either voluntary or compulsory. The procedure for compulsory acquisition is outlined in Section 16 of RA No. 6657, as amended. The Supreme Court emphasized that the issuance of a notice of coverage is the starting point of a proceeding for compulsory land acquisition and distribution under the agrarian reform program.

A notice of coverage informs the landowner that their land has been identified by the DAR as subject to agrarian reform. It also informs the landowner of their rights and obligations under the law, such as the right to retain land, nominate beneficiaries, and submit a list of tenants. Under DAR Administrative Order No. 01-03, the issuance of a notice of coverage marks the beginning of compulsory land acquisition. The Supreme Court therefore affirmed the RTC’s decision, holding that the DAR had jurisdiction over the matter because the proceedings were initiated before June 30, 2014. Consequently, the petition for quieting of title and declaratory relief filed by Robustum Agricultural Corporation was dismissed.

FAQs

What was the key issue in this case?	The key issue was whether the Department of Agrarian Reform (DAR) retained jurisdiction over agrarian reform matters initiated before June 30, 2014, even if the case was filed in court after that date.
What is a notice of coverage (NOC)?	A notice of coverage is a document issued by the DAR to inform a landowner that their land has been identified as subject to the agrarian reform program. It initiates the process of compulsory land acquisition and distribution.
What is Section 30 of RA No. 9700?	Section 30 of RA No. 9700 allows the DAR to continue processing and finalizing agrarian reform cases that were already pending as of June 30, 2014, even beyond that date. It clarifies that June 30, 2014 is the final date for initiating such proceedings.
What is compulsory land acquisition?	Compulsory land acquisition is the process by which the government, through the DAR, acquires private agricultural lands for distribution to qualified farmer beneficiaries, with compensation to the landowner.
What was the RTC’s decision in this case?	The Regional Trial Court (RTC) dismissed Robustum Agricultural Corporation’s petition, holding that it lacked jurisdiction over the matter because it pertained to the implementation of the agrarian reform program, which falls under DAR’s exclusive jurisdiction.
Why did Robustum Agricultural Corporation file a petition for quieting of title and declaratory relief?	Robustum Agricultural Corporation filed the petition to have its land declared free from the coverage of the agrarian reform program, arguing that the notice of coverage was improperly served and unenforceable.
What is the significance of the DAR’s quasi-judicial powers in this context?	The DAR’s quasi-judicial powers, as outlined in Section 50 of RA No. 6657, grant it primary jurisdiction to determine and adjudicate agrarian reform matters. This includes resolving disputes related to land acquisition and distribution.
What is the effect of this Supreme Court ruling?	This ruling affirms the DAR’s continued authority over agrarian reform cases initiated before June 30, 2014, even if legal challenges are filed after that date. It reinforces the DAR’s role in resolving agrarian disputes and implementing the agrarian reform program.

In conclusion, the Supreme Court’s decision in Robustum Agricultural Corporation v. Department of Agrarian Reform clarifies the extent of the DAR’s jurisdiction over agrarian reform cases following the enactment of RA No. 9700. The ruling ensures that the DAR retains the authority to finalize cases initiated before June 30, 2014, preventing parties from circumventing the agrarian reform process by filing suits in regular courts after the deadline. This decision provides important guidance for landowners, farmer beneficiaries, and the DAR itself, promoting clarity and consistency in the implementation of the agrarian reform program.

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: ROBUSTUM AGRICULTURAL CORPORATION VS. DEPARTMENT OF AGRARIAN REFORM AND LAND BANK OF THE PHILIPPINES, G.R. No. 221484, November 19, 2018