Dao-ayan v. The Department of Agrarian Reform Adjudication Board
REITERATIONFacts
The Antecedents: Petitioners, father and son Mariano and Marjun Dao-ayan, sought the annulment and cancellation of Certificate of Land Ownership Award (CLOA) No. 00371923 and TCT No. AT-9035 issued to respondent Araneta Landless Agrarian Reform Farmers Association (ALARFA). Lot No. 209, previously owned by Agricultural Research Farm Incorporated, was placed under the Comprehensive Agrarian Reform Program (CARP). Marjun initially filed an application as a farmer-beneficiary but was later delisted. ALARFA filed a petition to disqualify Mariano as a farmer-beneficiary, alleging he possessed substantial real properties. The DAR Regional Director disqualified Mariano, finding he was already a beneficiary of other landholdings under PD No. 27. Consequently, the DAR Regional Director issued the CLOA to ALARFA, leading to the issuance of TCT No. AT-9035 in ALARFA's name. Petitioners claimed they were not notified of the disqualification proceedings and the decision. The Provincial Agrarian Reform Officer (PARO) ordered ALARFA's installation on the lot and the occupants to vacate. Procedural History: Petitioners filed a complaint for Annulment and Cancellation of ALARFA's CLOA before the DARAB Regional Agrarian Reform Adjudicator on June 22, 1998. The DARAB Regional Adjudicator dismissed the complaint, holding that the DAR, not the DARAB, has the authority to identify and qualify beneficiaries, and that the Regional Director's resolution had become final and executory. The DARAB Central Office affirmed the dismissal, as did the Court of Appeals. The Petition: Petitioners elevated the case to the Supreme Court, raising two issues: (I) whether the DARAB Regional Adjudicator has jurisdiction over the annulment of registered CLOAs, and (II) whether the DAR Regional Director's decision disqualifying petitioners and awarding the CLOA to ALARFA had become final and executory.
Issue(s)
Whether the DARAB Regional Adjudicator has jurisdiction over the annulment of registered Certificates of Land Ownership Award (CLOAs). Whether the decision of the DAR Regional Director disqualifying petitioners and awarding the CLOA to respondent ALARFA has already become final and executory.
Ruling
The Petition is DENIED.
Ratio Decidendi
On the jurisdiction of the DARAB over the annulment of registered CLOAs: The Supreme Court affirmed that the DARAB has jurisdiction over cases involving the cancellation of registered Certificates of Land Ownership Award (CLOAs). This is based on Section 1, Rule II of the 1994 DARAB Rules of Procedure, which enumerates cases within the DARAB's exclusive original jurisdiction, including those involving the issuance, correction, and cancellation of CLOAs registered with the Land Registration Authority. The Court clarified that prior to registration, such cases fall under the DAR Secretary, but after registration, they fall under the DARAB. Since the CLOA in this case was registered with the Register of Deeds, the DARAB correctly assumed jurisdiction over the complaint for cancellation. On the finality of the DAR Regional Director's decision: The Supreme Court ruled that the decision of the DAR Regional Director disqualifying Mariano Dao-ayan as a farmer-beneficiary had become final and executory. While DAR Administrative Order No. 06-00, Series of 2000, was cited by the Court of Appeals regarding finality, it was deemed inapplicable as the events occurred prior to its issuance. However, the Court resorted to Section 15, Chapter 3, Book VII of the Administrative Code of 1987, which states that an agency's decision becomes final and executory fifteen (15) days after receipt of a copy by the adversely affected party, unless an appeal is perfected. The Court found no proof that petitioners were given notice of the proceedings before the DAR Regional Director. Nevertheless, it considered the registration of the CLOA on October 28, 1997, as constructive notice, or alternatively, the date petitioners filed a motion to stay execution on December 12, 1997. Since petitioners filed their complaint for annulment on June 22, 1998, which was more than fifteen days after either of these dates, the DAR Regional Director's resolution had long become final and executory. The DARAB, therefore, could not re-examine the merits of the disqualification.
Main Doctrine
The DARAB has jurisdiction over cases involving the cancellation of registered Certificates of Land Ownership Award (CLOAs). However, the determination of qualification or disqualification of farmer-beneficiaries falls under the exclusive jurisdiction of the DAR Secretary or his/her authorized representative. Decisions of the DAR Regional Director on such matters become final and executory if not appealed within the reglementary period, and the DARAB cannot re-examine the merits of such disqualification.