Lopez v. Romero
REITERATIONFacts
The Antecedents: The case involves two parcels of agricultural land registered in the name of respondent Reynald M. Romero, who holds Certificates of Land Ownership Award (CLOA) Nos. 70690 and 70691 issued by the Secretary of Agrarian Reform. Previously, these lots were covered by a CLOA in favor of Leonardo Briones. Petitioners Esperanza Vda. de Lopez and Modesta Vda. de Asuncion challenged the award to Briones. Briones executed a "Waiver of Rights" in favor of Erlinda Quintos, and subsequently another "Waiver of Rights" in favor of Reynald Romero, to whom he sold the lots for ₱2M. The PARAB granted Briones' petition for cancellation of his CLOA, leading to the issuance of CLOAs in Romero's name. An Order from the DAR Regional Office declared Briones disqualified and the landholdings open for disposition, giving preferential rights to petitioners, but this was not enforced due to the transfer to Romero. Later, the DAR Region III Director issued an Order disqualifying Romero as farmer-beneficiary, awarding the lots to petitioners, forfeiting Romero's payments, and directing petitioners to institute appropriate action for the cancellation of Romero's CLOAs. Procedural History: Respondent Romero filed a petition with the PARAB for "Maintenance of Peaceful Possession and Annulment/Cancellation of Order dated December 13, 1995 with Injunction," questioning the DAR Region III Director's Order for allegedly exceeding authority. Petitioners filed a Motion to Dismiss, arguing PARAB lacked jurisdiction as the order was administrative and should have been appealed to the DAR Secretary. PARAB denied the motion. Petitioners elevated the matter to the Court of Appeals (CA) via certiorari, which affirmed the PARAB's denial. The CA denied petitioners' motion for reconsideration. The Petition: Petitioners seek review of the CA's decision and resolution, primarily questioning whether PARAB Adjudicator Ilao, Jr. had jurisdiction to hear and decide Romero's case.
Issue(s)
Whether the Provincial Agrarian Reform Adjudication Board (PARAB) has jurisdiction to hear and decide DARAB Case No. 4098 P’96 concerning the rights of a CLOA holder. Whether the Order dated December 13, 1995, issued by DAR Region III Director Eugenio Bernardo, had become final and executory despite potentially being issued without jurisdiction.
Ruling
The petition is DENIED. The Court of Appeals did not commit reversible error in affirming the PARAB's denial of petitioners' motion to dismiss. The PARAB has jurisdiction over DARAB Case No. 4098 P’96.
Ratio Decidendi
On the jurisdiction of PARAB: The Court held that the PARAB has primary and exclusive original and appellate jurisdiction over agrarian disputes involving the implementation of the Comprehensive Agrarian Reform Program (CARP) and other agrarian laws. This jurisdiction includes cases concerning the rights and obligations of persons engaged in the management, cultivation, and use of agricultural lands covered by CARP, as well as the issuance, correction, and cancellation of Certificates of Land Ownership Award (CLOAs). In this case, respondent Romero's peaceful possession of the subject agricultural lands, which are registered in his name under TCT Nos. 4304 and 4305, constitutes an agrarian dispute. The Order dated December 13, 1995, issued by DAR Region III Director Eugenio Bernardo, directly affected Romero's rights as a CLOA awardee by disqualifying him and directing petitioners to seek cancellation of his CLOAs. Therefore, the PARAB, as the body vested with jurisdiction over such agrarian disputes, correctly took cognizance of Romero's petition. The Court emphasized that the DARAB New Rules of Procedure, specifically Rule II, Section 1(a), clearly grants this broad jurisdiction to the DARAB. On the finality of the DAR orders: The Court ruled that even if the DAR orders were not appealed, they could still be declared null and void if found to have been issued without jurisdiction. The principle that void judgments never become final and executory applies. The Court cited Leonor vs. Court of Appeals, which states that a void judgment for want of jurisdiction is no judgment at all and cannot be the source of any right. Furthermore, the Court noted that DAR Region III Director Bernardo himself, in his December 13, 1995 Order, directed petitioners to institute "appropriate action before the proper forum" for the cancellation of Romero's CLOAs. This implicitly recognized that his office lacked the jurisdiction to directly order the cancellation of CLOAs, which falls under the primary and exclusive original jurisdiction of the DARAB as per Rule II, Section 1(f) of the DARAB New Rules of Procedure.
Main Doctrine
The Provincial Agrarian Reform Adjudication Board (PARAB) has primary and exclusive original and appellate jurisdiction over agrarian disputes involving the implementation of the Comprehensive Agrarian Reform Program (CARP), including cases concerning the rights and obligations of persons engaged in the management, cultivation, and use of agricultural lands, and the issuance, correction, and cancellation of Certificates of Land Ownership Award (CLOAs).