Cabuguas v. Nery
REITERATIONFacts
1. The Antecedents: Respondent Gallant S. Tan Nery filed a complaint for recovery of possession of real property and ejectment against petitioners Wilfredo Cabuguas, Renato Cabuguas, Alejandro Canete, and Eleazar Mortus. The dispute concerns a 4,204-square meter parcel of land in Barangay San Jose, Malaybalay City, Bukidnon, covered by Transfer Certificate of Title (TCT) No. AT-15991 with Certificate of Land Ownership Award (CLOA) No. 00318948 issued to respondent. Respondent alleged that after hiring Wilfredo Cabuguas for land preparation, he and others occupied and cultivated the land, building structures thereon. Petitioners, however, claimed to be actual occupants and landless residents who had been possessing and cultivating portions of the land for a long time, asserting preferential rights as farmer-beneficiaries under RA 6657 and questioning the DARAB's jurisdiction. 2. Procedural History: The Provincial Agrarian Reform Adjudicator (PARAD) ruled in favor of respondent, ordering the petitioners to vacate the land and demolish structures. On appeal, the Department of Agrarian Reform Adjudication Board (DARAB-Central) reversed the PARAD's decision, dismissing the case for lack of jurisdiction and holding that the Secretary of DAR had jurisdiction. Respondent appealed to the Court of Appeals (CA), which reinstated the PARAD's decision, finding that the case involved an agrarian dispute within the DARAB's jurisdiction and that respondent's CLOA could not be collaterally attacked. Petitioners' motion for reconsideration was denied by the CA. 3. The Petition: Petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's decision and resolution. They argued that the CA erred in reversing the DARAB-Central's decision and in ruling that the DARAB had jurisdiction over the case. Petitioners attached a Certificate of Finality from the DAR Regional Office 10, referencing an order from the Secretary of DAR declaring respondent unqualified and petitioners as rightful beneficiaries. The Supreme Court, noting the potential significance of this new evidence but its uncertified status and the need for factual determination, remanded the case to the CA for further proceedings to allow both parties to present evidence regarding the status of the CLOA and its effect on the case.
Issue(s)
Whether the Court of Appeals erred in reversing the DARAB-Central's Decision and whether the DARAB has jurisdiction over the instant case. Whether the Court of Appeals erred in remanding the case for determination of factual issues.
Ruling
The Supreme Court remanded the case to the Court of Appeals for further proceedings. The CA is directed to allow petitioners to present proof of the status of the CLOA of the subject landholding and to allow respondent to present controverting evidence.
Ratio Decidendi
On the issue of jurisdiction and the CA's reversal of the DARAB-Central's Decision: The Court noted that the CA reinstated the PARAD's decision, finding that the complaint involved an agrarian dispute within the DARAB's jurisdiction. The CA also held that the respondent's CLOA could not be impeached or defeated by mere allegations of irregularity and that as a CLOA holder, the respondent was entitled to possess and recover the land. The Supreme Court, however, observed that petitioners attached a Certificate of Finality referencing an Order from the Secretary of the DAR which declared respondent unqualified and petitioners as rightful beneficiaries, directing the cancellation of respondent's CLOA. The Court found that while this indicated a separate action to assail the CLOA, the Certificate of Finality was not a certified true copy, and its validity and effect on the present case were factual matters that the Court could not determine. Therefore, to ensure fairness and speedy disposition, the case was remanded to the CA for further proceedings to allow both parties to present evidence regarding the status of the CLOA and their respective rights. On the propriety of remanding the case for determination of factual issues: The Court reiterated that it may, whenever necessary to resolve factual issues, delegate the reception of evidence to an appropriate court or agency. The CA, as a body fully capacitated and experienced in appreciating factual matters, including documentary evidence, is generally authorized to review findings of fact. The Court cited precedents where it resorted to referring factual matters to the CA for determination, consistent with Rules 32 and 46 of the Rules of Court, which allow for reference to a commissioner or delegation to an appropriate body for the reception and reporting of evidence on factual issues.
Main Doctrine
The Supreme Court remanded the case to the Court of Appeals for further proceedings to determine the validity of a Certificate of Land Ownership Award (CLOA) and the rights of the parties, considering a potentially conflicting final and executory decision from the Department of Agrarian Reform Secretary.