CRC 1447, Inc. v. Calbatea
REITERATIONFacts
The Antecedents: The case involves a portion of an estate originally owned by Liberty Hizon Vda. De Luna and Eufemia Rivera. In 1993, the estate was subjected to a Notice of Coverage under the Comprehensive Agrarian Reform Program (CARP). An application for conversion of the property from agricultural to industrial was granted, but the development was to be completed within five years. In 2004, Rivera sought an extension to comply with the development condition. CRC 1447, Inc. (petitioner) purchased the property in 2006. In 2007, the Department of Agrarian Reform (DAR) denied Rivera's extension request and issued a Notice of Coverage over the entire estate, including the subject property. Petitioner's petition to lift the Notice of Coverage was denied by the DAR in 2013. Procedural History: On February 26, 2014, petitioner filed a Complaint for Recovery of Possession before the Regional Trial Court (RTC) against respondents, who claimed to be actual occupants and potential agrarian reform beneficiaries. Respondents sought dismissal for lack of jurisdiction, arguing that the case involves an agrarian dispute falling under the DAR's competence. The RTC dismissed the case for lack of jurisdiction, finding that the determination of the validity of the Notice of Coverage was an agrarian matter. The RTC denied petitioner's motion for reconsideration. The Court of Appeals (CA) affirmed the RTC's dismissal, holding that the DAR has primary jurisdiction. The Petition: Petitioner seeks review, arguing that the RTC has jurisdiction over recovery of possession and that the Notice of Coverage does not automatically vest title or render the land a land reform area, thus not creating a tenancy relationship for DARAB's jurisdiction.
Issue(s)
Whether the Regional Trial Court (RTC) correctly dismissed the case for recovery of possession on the ground of lack of jurisdiction, considering the nature of the issues raised in the complaint. Whether the case involves an agrarian dispute falling under the primary jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB), given the actual occupants, potential agrarian reform beneficiaries, and the Notice of Coverage.
Ruling
The Supreme Court denied the petition, affirming the decision of the Court of Appeals which upheld the dismissal of the case by the Regional Trial Court for lack of jurisdiction. The Court ruled that the case involves an agrarian dispute and falls within the exclusive jurisdiction of the DARAB.
Ratio Decidendi
On the issue of jurisdiction over the case for recovery of possession: The Court reiterated that jurisdiction is conferred by law and determined by the allegations in the complaint. If the issues are intertwined with matters falling within the exclusive jurisdiction of the DARAB, the dispute must be resolved by the DARAB. Section 50 of Republic Act No. 6657, as amended by Republic Act No. 9700, vests the DAR with primary jurisdiction over agrarian reform matters and exclusive original jurisdiction over all matters involving the implementation of agrarian reform. Section 50-A clarifies that no court shall take cognizance of cases pertaining to CARP implementation, except those provided under Section 57, and any allegation of an agrarian nature shall lead to automatic referral to the DAR. The DARAB, created under Executive Order No. 129-A, assumes the powers and functions of the DAR in adjudicating agrarian reform cases. Section 1(a), Rule II of the 2009 DARAB Rules of Procedure grants the DARAB primary and exclusive original and appellate jurisdiction over cases involving the rights and obligations of persons engaged in the management, cultivation, and use of all agricultural lands covered by R.A. No. 6657, as amended. The Court found that while the complaint appeared to be for recovery of property, the fact that respondents are actual occupants and potential agrarian reform beneficiaries, coupled with the denial of petitioner's petition to lift the Notice of Coverage, established that the subject property is within the land reform area. Therefore, the issue of possession or use thereof falls within the jurisdiction of the DARAB. The petitioner's restrictive understanding of agrarian matters is unsustainable, as the DARAB's jurisdiction extends to all cases involving agrarian matters, including the management, cultivation, or use of agricultural lands covered by CARL, regardless of whether a tenancy relationship exists. A notice of coverage is not a prerequisite for DARAB jurisdiction over such cases. The issuance of the Notice of Coverage signifies that the DAR has determined the land to be under CARP coverage, making the case an agrarian matter, not merely an ordinary recovery of possession controversy. DAR Administrative Order No. 03-11 and OCA Circular No. 62-2010 reinforce the DAR's exclusive jurisdiction over agrarian matters and the referral of such cases by courts to the DAR.
Main Doctrine
The Regional Trial Court (RTC) correctly dismissed a complaint for recovery of possession when the subject property is covered by a Notice of Coverage under the Comprehensive Agrarian Reform Program (CARP), as such cases fall within the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB).