Cubero v. Laguna West Multi-Purpose Cooperative
REITERATIONFacts
The Antecedents: Individual petitioners Felixberto Cubero, Nerissa C. Natividad, Judy U. Lim, Manuel R. Lahoz, and Sotero Diola are the registered owners of approximately 78,178 square meters of land in Tanauan City, Batangas. In August 2003, they entered into a Joint Venture Development Agreement with Belle Corporation to develop these properties into an agricultural farm lot subdivision. Respondent Laguna West Multi-Purpose Cooperative, Inc. (Laguna West Cooperative) subsequently filed petitions for the inscription of an adverse claim, asserting that it had entered into separate Joint Venture Agreements (JVAs) with the individual petitioners' predecessors-in-interest as early as April 1996, and had registered these JVAs in August 2000. Procedural History: Laguna West Cooperative filed nine ex-parte petitions with the Regional Trial Court (RTC) of Tanauan City to rectify the alleged omission of its adverse claims on the Transfer Certificates of Title (TCTs) of the individual petitioners. In response, the petitioners filed a Complaint with the same RTC seeking the annulment of the JVAs, alleging they were void ab initio as they were executed within the ten-year prohibitory period under Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988) and constituted prohibited management contracts. The RTC dismissed the petitioners' complaint, ruling that the Department of Agrarian Reform (DAR), through its adjudication board (DARAB), has primary jurisdiction over such matters. The RTC denied the motion for reconsideration, leading to the present petition. The Petition: The petitioners seek a review on certiorari of the RTC's dismissal of their complaint, raising a pure question of law regarding jurisdiction. They argue that the RTC erred in deferring to the DARAB, contending that the JVAs are void ab initio due to violations of agrarian reform laws and public policy, and thus fall under the RTC's general jurisdiction. The Supreme Court, however, affirmed the RTC's dismissal, holding that the controversy, involving the rights and obligations of parties engaged in the management, cultivation, and use of agricultural land covered by CARP, falls squarely within the jurisdictional ambit of the DARAB, even if it raises legal or constitutional questions.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over the subject matter of the case, specifically the annulment of Joint Venture Agreements involving agricultural lands covered by agrarian reform laws. Whether the Joint Venture Agreements (JVAs) are void ab initio for being executed within the prohibitory period under Republic Act No. 6657 and for falling under prohibited management contracts.
Ruling
The petition is denied. The Regional Trial Court (RTC) correctly dismissed the complaint for lack of jurisdiction, as the case falls under the exclusive original jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB).
Ratio Decidendi
On the issue of jurisdiction over the subject matter: The Supreme Court reiterated the axiomatic principle that jurisdiction is determined by the allegations in the complaint and the character of the relief sought, as well as the status of the parties and the nature of the controversy. The Department of Agrarian Reform (DAR) is vested with primary and exclusive original jurisdiction over all matters involving the implementation of agrarian reform. The DARAB, as the adjudicative arm of the DAR, has jurisdiction to try and decide all agrarian disputes, cases, controversies, and matters or incidents involving the Comprehensive Agrarian Reform Program (CARP). This jurisdiction encompasses cases involving the rights and obligations of persons engaged in the management, cultivation, and use of agricultural lands covered by Republic Act No. 6657 and other agrarian laws. The RTC's dismissal was based on the understanding that the controversy involved the implementation of R.A. 6657, specifically whether the JVAs were violative of Sections 27 and 73 of the said Act, and whether the beneficiaries reneged on their obligations. The Court found that the RTC's restrictive view that the case did not involve an agrarian dispute was erroneous, as the scope of agrarian disputes extends beyond traditional tenurial relationships. The Supreme Court clarified that the DARAB has jurisdiction to determine and adjudicate all agrarian disputes involving the implementation of the CARL, including those arising from other tenurial arrangements beyond the traditional landowner-tenant or lessor-lessee relationship. The case of Islanders CARP-Farmers Beneficiaries Multi-Purpose Cooperative Development, Inc. v. Lapanday Agricultural and Development Corp. was cited, which held that the DARAB has jurisdiction over disputes arising from Joint Production Agreements. The Court emphasized that all controversies on the implementation of CARP fall under the jurisdiction of the DAR, even if they raise legal or constitutional questions, citing Department of Agrarian Reform v. Cuenca. On the nature of the dispute and the jurisdiction of DARAB: In the present case, the JVAs directly involve the development and utilization of agricultural lands covered by CARP, and the petitioners, as successors-in-interest, sought to nullify these agreements. Therefore, the controversy squarely falls within the jurisdictional ambit of the DAR, as it involves the rights and obligations of persons engaged in the management, cultivation, and use of agricultural land covered by CARP. The resolution of the case would principally entail a determination of alleged prohibited acts under Sections 27 and 73 of Republic Act No. 6645, and in such cases, the Court has consistently held that petitioners must first plead their case with the DARAB.
Main Doctrine
The Department of Agrarian Reform Adjudication Board (DARAB) has exclusive original jurisdiction over all matters involving the implementation of agrarian reform, including disputes arising from joint venture agreements concerning agricultural lands covered by Republic Act No. 6657, even if such disputes raise legal or constitutional questions.