Lakeview Golf v. Samahang Nayon
REITERATIONFacts
The Antecedents: Petitioner Lakeview Golf and Country Club, Inc. was the registered owner of a 60-hectare parcel of land. The Municipal Agrarian Reform Officer (MARO) issued a Notice of Coverage for the property under the Comprehensive Agrarian Reform Program (CARP). Petitioner protested the coverage, asserting the land was not agricultural, was mountainous with steep slopes, and that the alleged farmer-beneficiaries were intruders. The DAR Secretary denied the protest, and this denial was affirmed by the Court of Appeals and the Supreme Court. Procedural History: Subsequently, a collective Certificate of Land Ownership Award (CLOA) was issued in favor of private respondents. Petitioner filed a petition for cancellation of the CLOA and reconveyance with the Provincial Agrarian Reform Adjudicator (PARAD), arguing the land's mountainous nature and steep slope exempted it from CARP coverage. The PARAD ruled in favor of petitioner, declaring the CARP coverage and CLOA issuance erroneous. The Department of Agrarian Reform Adjudication Board (DARAB) reversed the PARAD's decision, holding that it lacked jurisdiction over CARP coverage issues and that the CLOA was valid. The Court of Appeals affirmed the DARAB's ruling. The Petition: Petitioner filed a petition for review with the Supreme Court, alleging that the Court of Appeals erred in finding that the DARAB did not have jurisdiction to rule on the issue of CARP coverage and in sustaining the DARAB's dismissal of the case.
Issue(s)
Whether the DARAB has jurisdiction to adjudicate the issue regarding the coverage of the subject property under the CARP. Whether the Court of Appeals erred in sustaining the DARAB's decision dismissing the case.
Ruling
The Supreme Court denied the petition for lack of merit, affirming the Decision of the Court of Appeals. The Court held that the DARAB has jurisdiction over cases involving the cancellation of registered CLOAs, but the issue of CARP coverage itself, including protests and petitions for lifting of coverage, falls under the exclusive jurisdiction of the DAR Secretary. Since the DAR Secretary had already ruled on the CARP coverage, and this ruling was affirmed by higher courts, the DARAB could not re-adjudicate this matter under the guise of canceling the CLOA.
Ratio Decidendi
On the jurisdiction of the DARAB over CARP coverage: The Court reiterated that jurisdiction over the subject matter is conferred by law. Section 50 of Republic Act No. 6657 and Section 17 of Executive Order No. 229 vest in the DAR the primary and exclusive jurisdiction over all matters involving agrarian reform implementation. While the DARAB has exclusive original jurisdiction over cases involving the cancellation of registered CLOAs, matters strictly involving the administrative implementation of CARP, such as classification and identification of landholdings for coverage, protests, oppositions, and petitions for lifting of coverage, are the exclusive prerogative of the DAR Secretary, as provided in Section 2 of DAR Administrative Order No. 06-00. The Court emphasized that the material averments of the petition invoking exemption from CARP coverage constrained it to look beyond the mere cancellation of a registered CLOA. The Court clarified the distinction based on the rules in effect at the time the petition was filed. Under the 1994 DARAB Rules of Procedure, the DARAB had exclusive original jurisdiction over cases involving the cancellation of registered CLOAs, while matters involving administrative implementation of CARL were within the exclusive prerogative of the DAR Secretary. The Court found that while the petition sought cancellation of a registered CLOA, the underlying issue raised was the CARP coverage itself, which was an administrative matter exclusively for the DAR Secretary. Thus, the DARAB correctly ruled that it had no jurisdiction to adjudicate the issue of CARP coverage. On the finality of the DAR Secretary's ruling on CARP coverage and the Court of Appeals' decision: The Court noted that the DAR Secretary had already denied petitioner's protest regarding CARP coverage and determined that the subject property was indeed covered. This ruling was affirmed by the Court of Appeals and the Supreme Court. Absent any palpable error, such determination on the coverage of the subject property under CARP is controlling. Therefore, the petitioner could not invoke the jurisdiction of the DARAB to pass upon the issue of CARP coverage under the guise of having the issued collective CLOA cancelled. The issue of coverage had already been definitively resolved by the proper administrative and judicial bodies.
Main Doctrine
The Department of Agrarian Reform Adjudication Board (DARAB) has jurisdiction over cases involving the issuance, correction, or cancellation of Certificates of Land Ownership Awards (CLOAs) that have been registered with the Land Registration Authority. However, matters strictly involving the administrative implementation of the Comprehensive Agrarian Reform Law (CARL), such as the classification and identification of landholdings for CARP coverage, including protests or oppositions thereto and petitions for lifting of coverage, fall within the exclusive prerogative and jurisdiction of the DAR Secretary.