Fernandez v. Fulgueras
REITERATIONFacts
1. The Antecedents: Petitioner Julian Fernandez filed a complaint with the Department of Agrarian Reform Adjudication Board (DARAB) seeking the nullification of an Emancipation Patent (EP) and reconveyance of a 1.7-hectare parcel of land in Mabitac, Laguna. Fernandez claimed he held a Certificate of Land Transfer for the land and had allowed respondent Rufino Fulgueras to till it since 1982, with shared harvests. However, the sharing ceased in 1996, and Fernandez later discovered the property was registered in Fulgueras's name under Transfer Certificate of Title No. TEP-436 in August 1999. 2. Procedural History: The Provincial Adjudicator initially dismissed Fernandez's complaint, deeming Fulgueras's title valid. A motion for reconsideration was denied. Fernandez then filed a petition for relief from judgment, citing his counsel's personal difficulties, which was also dismissed. An appeal was denied due to being an improper remedy. Subsequently, Fernandez filed a petition for certiorari with the DARAB, which reversed the Provincial Adjudicator's decision, declared the EP void, and ordered a new EP issued to Fernandez. Upon respondent's motion for reconsideration, the DARAB denied it. Respondent then filed a petition for certiorari with the Court of Appeals (CA), which was treated as a petition for review under Rule 43. The CA reversed the DARAB's decision, reinstating the Provincial Adjudicator's ruling. The CA later denied Fernandez's motion for reconsideration. 3. The Petition: This case reaches the Supreme Court via a petition for review on certiorari under Rule 45 of the Rules of Court, challenging the CA's decision and resolution. Petitioner argues that the CA erred in reversing the DARAB's decision. The core issue is whether the DARAB possessed jurisdiction to issue a writ of certiorari to assail an interlocutory order of the Provincial Adjudicator, as provided by Section 3, Rule VIII of the DARAB New Rules of Procedure. The Supreme Court, referencing its ruling in DARAB v. Lubrica, determined that the DARAB lacks the statutory authority to issue writs of certiorari, as such jurisdiction was not expressly granted by law, and therefore, the DARAB's decision was void for having been issued without jurisdiction.
Issue(s)
Whether the DARAB has jurisdiction to entertain a petition for certiorari. Whether the Court of Appeals erred in reversing the DARAB decision.
Ruling
The petition is denied. The Court of Appeals Decision dated February 25, 2007, and Resolution dated June 8, 2007, are affirmed. The DARAB decision was void for having been issued without jurisdiction.
Ratio Decidendi
On the issue of DARAB's jurisdiction to entertain a petition for certiorari: The Supreme Court held that the DARAB, as a quasi-judicial body, possesses only limited jurisdiction, which is conferred by law. The DARAB's New Rules of Procedure, which allowed for a petition for certiorari to assail an interlocutory order, were found to be an invalid exercise of rule-making power as they attempted to grant jurisdiction not expressly provided by statute. The Court, citing DARAB v. Lubrica, emphasized that jurisdiction cannot be self-conferred by rules of procedure; it must originate from substantive law. Therefore, the DARAB acted without jurisdiction when it entertained the petition for certiorari filed by the petitioner. The proper venue for such a petition would have been the regular courts, absent any specific statutory grant of certiorari jurisdiction to the DARAB. On whether the Court of Appeals erred in reversing the DARAB decision: The Court of Appeals correctly set aside the DARAB decision because the DARAB acted without jurisdiction. Since the DARAB's decision was void ab initio, it had no legal effect. The CA, in granting the petition for certiorari filed by the respondent, correctly nullified the DARAB's resolution. The CA's action in treating the petition for certiorari as a petition for review under Rule 43 was also appropriate in the interest of substantial justice and to expedite the resolution of the case. Consequently, the CA did not err in reversing the DARAB decision and upholding the original decision of the Provincial Adjudicator.
Main Doctrine
The Department of Agrarian Reform Adjudication Board (DARAB), as a quasi-judicial body with limited jurisdiction, cannot exercise jurisdiction over petitions for certiorari in the absence of a specific statutory grant of such power. Jurisdiction over the subject matter is conferred by law, and rules of procedure cannot expand this authority.