Philippine Veterans Bank v. Cruz
REITERATIONFacts
The Antecedents: Philippine Veterans Bank (PVB) received Notices of Acquisition from the Department of Agrarian Reform (DAR) placing its agricultural properties in Baliwag, Bulacan, under the Comprehensive Agrarian Reform Law coverage. These properties were designated for beneficiaries, including private respondents Lazaro N. Cruz and Francisco T. Cruz, who were issued Certificates of Land Ownership Award (CLOA). Procedural History: PVB filed a petition with the Regional Trial Court (RTC) of Malolos, Bulacan, seeking the annulment of the CLOAs, asserting the lands were outside CARP coverage. Concurrently, private respondents filed a complaint with the DAR Adjudication Board (DARAB) for maintenance of possession, alleging PVB fenced off the properties. The DAR Provincial Adjudicator ordered PVB to cease and desist from ejecting the private respondents. Respondents moved to dismiss the RTC case, citing DARAB's exclusive jurisdiction. The RTC denied this motion. Subsequently, respondents filed a Petition for Certiorari and Prohibition with the Court of Appeals (CA). Initially, the CA denied the petition, finding DARAB lacked jurisdiction due to the alleged non-registration of the CLOAs. However, upon motion for reconsideration, the CA reversed its ruling, finding the CLOAs had been entered in the Primary Entry Book of the Register of Deeds, thus establishing DARAB's primary and exclusive jurisdiction and annulling the RTC's order. PVB's subsequent motion for reconsideration was denied by the CA. The Petition: Aggrieved by the CA's decision, PVB filed a petition for certiorari, which this Court treated as a petition for review under Rule 45. PVB argues that the CA gravely abused its discretion in holding that the case involves an agrarian dispute within DARAB's exclusive jurisdiction, that cases for annulment of CLOA fall under DARAB's jurisdiction, that DARAB has jurisdiction despite its adjudicator being a party, and that DARAB has jurisdiction even though the property ceased to be agricultural. PVB also questioned the constitutionality of a DARAB rule, a claim raised belatedly in its memorandum.
Issue(s)
Whether the Court of Appeals gravely abused its discretion in holding that the case involves an agrarian dispute within the exclusive jurisdiction of DARAB. Whether the Court of Appeals gravely abused its discretion in ruling that cases for annulment of CLOA fall within the jurisdiction of DARAB. Whether the Court of Appeals gravely abused its discretion in holding that the DARAB has jurisdiction notwithstanding that the DARAB adjudicator is himself a party to the case. Whether the Court of Appeals gravely abused its discretion in ruling that the DARAB has jurisdiction notwithstanding the fact that the property ceased to be agricultural.
Ruling
The petition is denied for lack of merit. The Court of Appeals did not commit grave abuse of discretion.
Ratio Decidendi
On the jurisdiction of DARAB over agrarian disputes: The Court reiterated that jurisdiction is determined by the allegations in the complaint. PVB's complaint for annulment of CLOA, which it alleged to be illegally and fraudulently issued concerning agricultural land, clearly falls within the ambit of agrarian reform matters. Section 1, Rule II of the DARAB Rules of Procedure explicitly grants the DARAB primary and exclusive jurisdiction over all agrarian disputes and matters involving the implementation of the Comprehensive Agrarian Reform Program (CARP), including cases involving the issuance and cancellation of CLOAs. The Court cited numerous precedents, such as SSS v. DAR, Centeno v. Centeno, and Rivera v. Del Rosario, which consistently uphold DARAB's jurisdiction over such cases. The definition of "agrarian dispute" under Section 3(d) of R.A. 6657 further supports this, encompassing controversies relating to compensation of lands acquired under the Act and terms of transfer of ownership to beneficiaries. On the jurisdiction of DARAB over annulment of CLOAs: The Court reiterated that jurisdiction is determined by the allegations in the complaint. PVB's complaint for annulment of CLOA, which it alleged to be illegally and fraudulently issued concerning agricultural land, clearly falls within the ambit of agrarian reform matters. Section 1, Rule II of the DARAB Rules of Procedure explicitly grants the DARAB primary and exclusive jurisdiction over all agrarian disputes and matters involving the implementation of the Comprehensive Agrarian Reform Program (CARP), including cases involving the issuance and cancellation of CLOAs. The Court cited numerous precedents, such as SSS v. DAR, Centeno v. Centeno, and Rivera v. Del Rosario, which consistently uphold DARAB's jurisdiction over such cases. The definition of "agrarian dispute" under Section 3(d) of R.A. 6657 further supports this, encompassing controversies relating to compensation of lands acquired under the Act and terms of transfer of ownership to beneficiaries. On the jurisdiction of DARAB despite the DARAB adjudicator being a party: The Court clarified that jurisdiction is conferred by law based on the allegations in the complaint, not on who the parties are. While PVB impleaded the DAR Provincial Adjudicator in his official capacity, this does not divest the DARAB of jurisdiction. The Court noted that it is doubtful if the same adjudicator would be tasked to hear and rule on the matter if the case were filed before the DARAB, given the potential conflict of interest. On the jurisdiction of DARAB despite the property ceasing to be agricultural: The Court held that PVB's claim that the property ceased to be agricultural was a matter whose veracity had yet to be verified. The initial allegations in PVB's complaint stated that the property was agricultural, thus establishing jurisdiction with the DARAB at the outset. Subsequent claims about the property's status do not automatically divest the DARAB of jurisdiction, especially when the core issue remains the validity and implementation of agrarian reform awards.
Main Doctrine
The Department of Agrarian Reform Adjudication Board (DARAB) has primary and exclusive jurisdiction over cases involving the issuance, correction, partition, cancellation, secondary and subsequent issuances of Certificates of Land Ownership Award (CLOA), as these fall under agrarian disputes and matters involving the implementation of the Comprehensive Agrarian Reform Program (CARP).