In Lucero v. Delfino, the Supreme Court affirmed the cancellation of Certificates of Land Ownership Award (CLOAs) issued to farmer beneficiaries due to violations of the original landowners’ right to due process in the Comprehensive Agrarian Reform Program (CARP). This ruling underscores the importance of adhering to procedural requirements in land reform, particularly respecting landowners’ rights to choose their retained areas. The decision reinforces that CLOAs, while generally indefeasible, can be revoked if issued in violation of agrarian reform laws.

Landowners’ Due Process vs. Farmers’ Rights: When Can CLOAs Be Cancelled?

This case revolves around a parcel of land in Laguna, initially owned by Rory and Isabelita Delfino, which was later placed under CARP coverage. The Luceros, claiming to be tenants, were eventually granted CLOAs over portions of the land. However, the Delfinos contested the CLOAs, asserting that their rights to due process were violated because they were not properly consulted regarding the selection of their retained areas. This dispute raises a fundamental question: Under what circumstances can a CLOA, which grants land ownership to farmer beneficiaries, be cancelled to protect the rights of the original landowner?

The central issue in this case is whether the Department of Agrarian Reform Adjudication Board (DARAB) had jurisdiction to order the cancellation of the CLOAs issued to the Luceros, and whether those CLOAs had already become indefeasible. The Luceros argued that the DARAB lacked jurisdiction because there was no genuine agrarian dispute, and that the CLOAs, having been registered under the Torrens system, were protected from cancellation. The Delfinos, on the other hand, maintained that the DARAB had jurisdiction, and that the CLOAs were properly cancelled because their right to due process was violated during the CARP implementation.

The Supreme Court addressed the issue of jurisdiction by clarifying the roles of the DAR Secretary and the DARAB in CLOA cancellation cases. While the DAR Secretary has jurisdiction over administrative implementation of agrarian reform laws, the DARAB has primary jurisdiction over cases involving the cancellation of registered CLOAs, but only when such cases involve an agrarian dispute. An agrarian dispute is defined as any controversy relating to tenurial arrangements, whether leasehold, tenancy, stewardship, or otherwise, over lands devoted to agriculture. This definition is crucial because it establishes the necessary link between the parties for the DARAB to exercise its authority.

In this case, the Court found that the Luceros themselves had previously claimed to be tenants of the subject lands. The Court noted that the Luceros explicitly stated in their memorandum that they were the rightful tenants of the subject lands. The court, therefore, affirmed the existence of a tenancy relationship, thus establishing the presence of an agrarian dispute and validating the DARAB’s jurisdiction to hear the case.

The Court then considered the argument that the CLOAs had become indefeasible due to their registration under the Torrens system. While acknowledging that CLOAs are generally entitled to the same level of indefeasibility as other certificates of title, the Court emphasized that this principle does not apply when the CLOAs were issued in violation of agrarian reform laws. The Court cited the case of Polo Plantation Agrarian Reform Multipurpose Cooperative (POPARMUCO) v. Inson, which states that rights of registered property owners may be forfeited in case of violations of agrarian laws, as well as noncompliance with the restrictions and conditions under the Comprehensive Agrarian Reform Law. Further, the Court also made reference to Daez v. Court of Appeals, elucidating that CLOAs may be cancelled if the same were issued in violation of agrarian reform laws, such as a landowner’s right of retention.

Specifically, the Court highlighted that the Delfinos’ cancellation case hinged on the violation of their right to due process, lack of compensation, and the denial of their right to choose the area to be retained. The Court found that the PARAD and the DARAB correctly determined that the Delfinos’ right to due process in relation to their right of retention had indeed been violated. As a result, the cancellation of the CLOAs issued in favor of the Luceros was deemed warranted.

The Supreme Court’s decision underscores the importance of due process in agrarian reform. Landowners must be properly notified and consulted regarding the placement of their lands under CARP and their right to choose their retained areas. The ruling also highlights that while CLOAs provide security of tenure to farmer beneficiaries, they are not absolute and can be cancelled if procedural requirements are not met.

The case serves as a reminder to agrarian reform implementers to strictly adhere to the rules and regulations governing CARP, particularly those relating to due process and landowners’ rights. It also reinforces the principle that the goals of agrarian reform must be balanced with the constitutional rights of landowners. By affirming the cancellation of the CLOAs, the Supreme Court has upheld the rule of law and ensured that agrarian reform is implemented in a just and equitable manner.

FAQs

What was the key issue in this case?	The key issue was whether the CLOAs issued to the Luceros were valid, given the Delfinos’ claim that their right to due process was violated during the land acquisition process under CARP. The court examined whether the DARAB had jurisdiction and if the CLOAs were indefeasible.
What is a CLOA?	A Certificate of Land Ownership Award (CLOA) is a document issued to qualified farmer beneficiaries under the Comprehensive Agrarian Reform Program (CARP), granting them ownership of agricultural land. It serves as the title to the land, similar to a transfer certificate of title.
What does indefeasibility mean in the context of a CLOA?	Indefeasibility means that a CLOA, once registered, becomes generally protected from cancellation after a certain period. However, this protection is not absolute and can be challenged if the CLOA was issued in violation of agrarian reform laws or due process rights.
Under what circumstances can a CLOA be cancelled?	A CLOA can be cancelled if it was issued in violation of agrarian reform laws, such as failing to respect a landowner’s right to due process or retention rights. Other grounds include fraud, misrepresentation, or violation of the terms and conditions of the CLOA.
What is the role of DARAB in CLOA cancellation cases?	The Department of Agrarian Reform Adjudication Board (DARAB) has the authority to hear and decide cases involving the cancellation of registered CLOAs, provided that the case involves an agrarian dispute. This jurisdiction is exclusive and primary.
What is considered an agrarian dispute?	An agrarian dispute is any controversy relating to tenurial arrangements, whether leasehold, tenancy, stewardship, or otherwise, over lands devoted to agriculture. It includes disputes concerning the terms and conditions of these arrangements and the compensation for lands acquired under agrarian reform.
What is a landowner’s right of retention under CARP?	Under CARP, landowners have the right to retain a certain portion of their agricultural land, typically five hectares. This right is subject to certain conditions and requirements, including the need to properly notify and consult with the Department of Agrarian Reform (DAR).
What happens if a landowner’s right to due process is violated during CARP implementation?	If a landowner’s right to due process is violated, such as by failing to provide proper notice or consultation, the resulting land acquisition and distribution may be invalidated. This can lead to the cancellation of CLOAs issued to farmer beneficiaries and the return of the land to the landowner.

The Lucero v. Delfino case reinforces the balance between protecting the rights of farmer beneficiaries and upholding the due process rights of landowners in agrarian reform. The decision serves as a guide for future CARP implementation, emphasizing the need for strict adherence to procedural rules and regulations.

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: Herman Lucero and Virgilio Lucero, vs. Rory Delfino and Isabelita Delfino, G.R. No. 208191, September 29, 2021