In Romeo M. Landicho v. William C. Limqueco, the Supreme Court addressed the jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB) over disputes involving lands awarded under the Comprehensive Agrarian Reform Program (CARP). The Court held that DARAB has the authority to hear cases concerning the transfer of Certificate of Land Ownership Awards (CLOAs) and the rights of agrarian reform beneficiaries, even if there is no direct landlord-tenant relationship. This decision clarifies that controversies related to the terms and conditions of land ownership transfer under CARP fall within DARAB’s jurisdiction, ensuring protection for agrarian reform beneficiaries and promoting the goals of agrarian reform.

Landicho vs. Limqueco: When Does Selling Farmlands Break Agrarian Reform?

The case originated from petitions filed by agrarian reform beneficiaries seeking to nullify contracts of sale involving their awarded lands, as well as the recovery of their CLOAs. The petitioners, who were awarded land under the CARP, claimed that the respondent, William C. Limqueco, acquired their lands through fraudulent means and violated the restrictions on land transfer imposed by Republic Act (R.A.) No. 6657, the Comprehensive Agrarian Reform Law of 1988 (CARL). The central issue was whether the DARAB had jurisdiction over the dispute, considering the absence of a direct landlord-tenant relationship between the parties.

The Court of Appeals (CA) reversed the DARAB’s decision, stating that the DAR Secretary, not the PARAD/DARAB, had jurisdiction over the petitions because there was no agrarian dispute. The Supreme Court disagreed with the CA’s interpretation. The Supreme Court emphasized that the definition of an agrarian dispute under Section 3(d) of the CARL encompasses controversies related to the compensation of lands acquired under CARP and other terms and conditions of transfer of ownership from landowner to farmworkers, tenants, and other agrarian reform beneficiaries. This applies whether or not the disputants have a direct relationship as farm operator and beneficiary, landowner and tenant, or lessor and lessee.

Building on this principle, the Supreme Court examined the allegations made by the petitioners in their complaints. The Court noted that the petitioners invoked their rights as beneficiaries of the CARL, contending that the conveyance of their properties was made in violation of the terms and conditions of the CARL, and that the transfers should be nullified due to fraud, undue influence, and mistake. These allegations, the Court reasoned, constituted an agrarian dispute because the core of the controversy related to the terms and conditions of transfer of ownership from landowner to agrarian reform beneficiaries.

Moreover, the Supreme Court referred to the DARAB New Rules of Procedure, which were adopted and promulgated on May 30, 1994, and came into effect on June 21, 1994 after publication (1994 DARAB Rules). The 1994 DARAB Rules identified the cases over which the DARAB shall have jurisdiction, to wit:

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:

The Court highlighted the fact that the DARAB’s jurisdiction extends to cases involving the sale, alienation, mortgage, foreclosure, pre-emption, and redemption of agricultural lands under the coverage of the CARP or other agrarian laws, as well as 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.

This approach contrasts with the CA’s reliance on the absence of a landlord-tenant relationship. The CA’s perspective would unduly restrict the scope of agrarian disputes and undermine the DARAB’s mandate to protect the rights of agrarian reform beneficiaries. Therefore, the Supreme Court firmly rejected this narrow interpretation, reinforcing the DARAB’s crucial role in resolving disputes arising from the implementation of agrarian reform laws.

The Court also addressed procedural issues raised by the petitioners. One such issue was that respondent’s recourse to the CA via Rule 43 was improper because the correct remedy should have been a special civil action for certiorari under Rule 65 because the DARAB or PARAD lacked jurisdiction over the cases. The Supreme Court clarified that it was proper because, respondent impugns the jurisdiction of the DARAB and PARAD over the cases filed by the petitioners. In other words, the question posed before the CA pertained to jurisdiction over the subject matter of a case. In Sevilleno v. Carilo the Court has reiterated that such kind of question is a pure question of law. Thus, considering that Section 3, Rule 43 of the Rules of Court permits appeal whether the questions involved are of fact, of law or both, respondent’s resort via Rule 43 was certainly proper.

As a final point, the Court remanded the case to the CA for a proper review of the substantive issues raised by the parties concerning the legality of the transfer of the properties to the respondent. This was because the appellate court had not made a ruling on whether fraud, undue influence, and mistake had occasioned the procurement by respondent of the titles to the properties and whether there was indeed a violation of the CARL.

FAQs

What was the central legal question in this case?	The key issue was whether the DARAB had jurisdiction over disputes involving lands awarded under the CARP when there was no direct landlord-tenant relationship between the parties. The Supreme Court determined that DARAB did have jurisdiction.
What is a Certificate of Land Ownership Award (CLOA)?	A CLOA is a title document awarded to beneficiaries of the Comprehensive Agrarian Reform Program (CARP), granting them ownership of agricultural land. It is a key instrument in the redistribution of land to landless farmers.
What does the Comprehensive Agrarian Reform Law (CARL) aim to achieve?	The CARL, or R.A. No. 6657, seeks to promote social justice and equitable distribution of land resources by redistributing agricultural lands to landless farmers and farmworkers. The law also aims to improve agricultural productivity and uplift the socio-economic conditions of rural communities.
What is an agrarian dispute, according to the Supreme Court?	The Supreme Court stated that an agrarian dispute includes controversies relating to the compensation of lands acquired under CARP and the terms and conditions of transfer of ownership from landowner to agrarian reform beneficiaries. This definition applies regardless of the existence of a direct landlord-tenant relationship.
What was the Court of Appeals’ view on the jurisdiction of the DARAB?	The Court of Appeals held that the DAR Secretary, and not the PARAD/DARAB, had jurisdiction to hear the subject petitions in the absence of an agrarian dispute. The Supreme Court disagreed with this interpretation.
Why did the Supreme Court remand the case to the Court of Appeals?	The Supreme Court remanded the case because the Court of Appeals had not yet passed upon the question of whether fraud, undue influence, and mistake had influenced the procurement by the respondent of the titles to the properties. Also, they did not make a determination of whether there was indeed a violation of the CARL.
What is the significance of the ruling in Landicho v. Limqueco?	This ruling clarifies and reinforces the DARAB’s jurisdiction over disputes involving lands awarded under the CARP, ensuring the protection of the rights of agrarian reform beneficiaries. It also prevents parties from circumventing agrarian reform laws through fraudulent land transfers.
Can agrarian reform beneficiaries freely sell their awarded lands?	No, agrarian reform beneficiaries are subject to restrictions on the sale, transfer, or conveyance of land for a period of ten (10) years, except through hereditary succession, to the government, or to the Land Bank of the Philippines, or to other qualified beneficiaries.

The Supreme Court’s decision in Landicho v. Limqueco provides critical guidance on the jurisdiction of the DARAB in agrarian disputes, particularly those involving the transfer of CLOAs and the rights of agrarian reform beneficiaries. The ruling emphasizes that the absence of a direct landlord-tenant relationship does not necessarily preclude the DARAB’s jurisdiction, as long as the controversy relates to the terms and conditions of land ownership transfer under CARP. The Court’s ruling serves to protect the rights of agrarian reform beneficiaries and promote the goals of agrarian reform.

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: Romeo M. Landicho, vs. William C. Limqueco, G.R No. 194556, December 07, 2016