Fagel Tabin Agricultural Corporation v. Jacinto
REITERATIONFacts
The Antecedents: Petitioner Fagel Tabin Agricultural Corporation (formerly Davao Industrial Development Co.) owned a 165-hectare agricultural land. In March 1973, officials of the Ministry of Agrarian Reform (MAR) conducted parcellary map sketching on portions of this land, classifying them under Operation Land Transfer (OLT) pursuant to Presidential Decree No. 27. Subsequently, 35 Certificates of Land Transfer (CLTs) covering 43.51 hectares were issued to alleged tenant-beneficiaries. Procedural History: On June 3, 1980, petitioner filed a complaint with the Court of Agrarian Relations (CAR), Branch I, Davao City, seeking the declaration of nullity of the issued CLTs. Petitioner argued that the CLTs were illegally and unlawfully issued because the land was primarily devoted to coconut and rubber, not rice and corn, which are the primary focus of P.D. 27. Petitioner also alleged grave abuse of authority and utter lack of jurisdiction by the MAR officials. The respondents, including the MAR officials and alleged tenant-beneficiaries, contended that the landholding was not entirely devoted to coconuts and rubber and that only tenanted portions devoted to corn were placed under OLT. They further argued that the CAR lacked jurisdiction under Section 12(b) of P.D. 946, which vests exclusive jurisdiction over administrative implementation matters of P.D. 27 in the Secretary of Agrarian Reform. The CAR, after preliminary hearing, dismissed the complaint for lack of jurisdiction in a Resolution dated September 4, 1980. Petitioner's motion for reconsideration was denied on October 15, 1980. The Petition: Petitioner filed a petition for certiorari and mandamus with the Supreme Court, seeking to set aside the CAR's dismissal resolution and order.
Issue(s)
Whether the Court of Agrarian Relations erred in dismissing the complaint for lack of jurisdiction. Whether Presidential Decree No. 27 includes in its coverage portions of land primarily devoted to coconut, rubber, and other permanent trees, and the mootness of the case due to the enactment of Republic Act No. 6657. Whether the burden of proof under the referral provisions/proviso of the 2nd paragraph of P.D. No. 946 is upon the respondents, and whether the proviso must be strictly construed.
Ruling
The petition is dismissed for lack of merit and having been rendered moot and academic.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court affirmed the dismissal of the case by the Court of Agrarian Relations for lack of jurisdiction. The Court emphasized that Section 12(b) of P.D. 946 clearly provides that matters involving the administrative implementation of the transfer of land to tenant-farmers under P.D. 27 are exclusively cognizable by the Secretary of Agrarian Reform. This includes classification and identification of landholdings, parcellary mapping, and the issuance, recall, or cancellation of Certificates of Land Transfer. The Court held that the provision is clear and unambiguous, and therefore, must be taken to mean exactly what it says. If the petitioner disagreed with the MAR's placement of the landholding under OLT, the proper recourse was to file the complaint with the Ministry of Agrarian Reform, not the Court of Agrarian Relations. The Court reiterated the principle that courts must first apply the law as written before resorting to interpretation. On the scope of P.D. 27 and the mootness of the case: While the Court did not directly rule on whether P.D. 27 covers lands primarily devoted to coconut and rubber, it implicitly addressed this by stating that the CAR lacked jurisdiction over the administrative implementation of OLT. The petitioner's argument that the land was primarily devoted to coconut and rubber was the basis for their claim that P.D. 27 was inapplicable and thus the CLTs were void. However, the Court's focus remained on the jurisdictional aspect, deeming the classification and identification of landholdings as administrative matters falling under the exclusive cognizance of the Secretary of Agrarian Reform. The Court noted that the case had become moot and academic due to the enactment of Republic Act No. 6657, the Comprehensive Agrarian Reform Law of 1988. Section 4(d) of R.A. 6657 includes in its coverage all private lands devoted to or suitable for agriculture, regardless of the agricultural products raised thereon. This new law effectively covers the landholding in question, rendering the dispute over the applicability of P.D. 27 and the validity of the CLTs under that decree moot. On the burden of proof and construction of the proviso: The Court did not extensively discuss the burden of proof or the strict construction of the proviso in relation to the petitioner's arguments. Instead, it relied on the clear language of Section 12(b) of P.D. 946 to determine jurisdiction. The Court's application of the statute demonstrated that the primary consideration was the explicit grant of exclusive administrative jurisdiction to the Secretary of Agrarian Reform over matters concerning the implementation of P.D. 27, rendering the petitioner's specific arguments about the land's primary crop secondary to the jurisdictional question.
Main Doctrine
The Court of Agrarian Relations has no jurisdiction over matters involving the administrative implementation of the transfer of land to tenant-farmers under Presidential Decree No. 27, which are exclusively cognizable by the Secretary of Agrarian Reform as provided in Section 12(b) of P.D. 946. Cases filed before the Court of Agrarian Relations concerning such administrative matters are dismissible for lack of jurisdiction.