Heirs of Santos v. Court of Appeals
REITERATIONFacts
The Antecedents: The underlying dispute concerns a parcel of land in Parulan, Plaridel, Bulacan. This land was levied on execution by the Municipal Trial Court of Plaridel, Bulacan, on October 24, 1989, and subsequently sold at public auction on September 20, 1990. Herman Rey Santos emerged as the sole bidder and registered the Deed of Sale. After the private respondent failed to exercise his right of redemption, a Final Deed of Sale was executed in favor of Santos. Procedural History: The controversy escalated when the private respondent filed a Petition for Injunction and Damages with the Department of Agrarian Reform Adjudication Board (DARAB), seeking to prevent the petitioner from gathering mango fruits from the land. The DARAB issued an order allowing the gathering of fruits and directing the deposit of proceeds. Subsequently, a motion to intervene was filed by Pantaleon Antonio, claiming rights as the party who tended the mango trees. The DARAB later recognized Antonio as an agricultural tenant and allowed him to withdraw a portion of the harvest proceeds. The Court of Appeals affirmed these DARAB orders. The Petition: The petitioners, heirs of the late Herman Rey Santos, seek a review on certiorari of the Court of Appeals' decision. They argue that the Court of Appeals erred in ruling that the Provincial Agrarian Reform Adjudicator (PARAD) had jurisdiction over the ancillary matters raised by the intervenor, especially given the admitted issue of ownership pending before a regional trial court. Furthermore, they contend that the PARAD improperly allowed the release of harvest proceeds to the intervenor without due process and without requiring a bond, during a period when the principal case was indefinitely suspended. The petitioners assert that the DARAB lacked jurisdiction as no agrarian dispute was involved, but rather a question of ownership.
Issue(s)
Whether the Provincial Agrarian Reform Adjudicator (PARAD) has jurisdiction over the ancillary matter of gathering mango fruits and their proceeds when the principal issue involves ownership of the land, considering the absence of an agrarian dispute. Whether the DARAB properly took cognizance of Pantaleon Antonio's motion for intervention and allowed the withdrawal of his share of the harvest proceeds, given the lack of jurisdiction over the principal issue of ownership and the absence of an agrarian relationship.
Ruling
The petition is GRANTED. The assailed decision of the Court of Appeals is REVERSED and SET ASIDE. The DARAB is permanently enjoined from hearing the motion for intervention of Pantaleon Antonio, who is ordered to redeposit P87,300.00 with the Regional Trial Court. The DARAB is also ordered to transfer the remaining P87,300.00 on deposit with it to the Regional Trial Court.
Ratio Decidendi
On the issue of jurisdiction over ancillary matters and the intervention: The Supreme Court ruled that the DARAB does not have jurisdiction over the case because no agrarian dispute is involved. The core issue is one of ownership between the parties, which falls under the jurisdiction of the regular courts. Rule II, Section 1 of the Revised Rules of Procedure of the DARAB grants it primary jurisdiction over "agrarian disputes, cases, controversies, and matters or incidents involving the implementation of the Comprehensive Agrarian Reform Program." An agrarian dispute is defined under Section 3(d) of Republic Act No. 6657 as a controversy relating to tenurial arrangements over agricultural lands. In this case, the parties are contending for ownership, and there is no existing tenurial, leasehold, or agrarian relationship between them. Therefore, the DARAB should not have taken cognizance of the private respondent's petition for injunction. On the issue of the motion for intervention and withdrawal of proceeds: Since the DARAB lacked jurisdiction over the main controversy, any ancillary matter, such as the gathering of fruits or the intervention of Pantaleon Antonio, also falls outside its competence. The Court reiterated the ruling in Morta v. Occidental that for DARAB to have jurisdiction, a tenancy relationship must exist, with all its indispensable elements, which are absent here. The DARAB itself admitted that the issue involved was a question of ownership. The issue of who can harvest the mangoes and when is dependent on the resolution of the ownership dispute, which is properly cognizable by the RTC. Consequently, the motion for intervention, lacking a jurisdictional basis, could not stand. The DARAB should not have allowed the withdrawal of the intervenor's share, as this action was taken without jurisdiction and during the supposed suspension of the principal case.
Main Doctrine
The Department of Agrarian Reform Adjudication Board (DARAB) lacks jurisdiction over cases that do not involve an agrarian dispute, particularly when the core issue is ownership of the property, which falls under the jurisdiction of regular courts.