Abella v. Villan
REITERATIONFacts
The Antecedents: Eutiquiano T. Armario was a farmer-beneficiary of four farmlots. His Municipal Agrarian Reform Officer (MARO) initially recommended that an excess area of 0.4289 hectares be transferred to his son-in-law, Reynaldo Abella. Later, a different MARO recommended that 0.9712 hectares be transferred to Abella. Abella, married to Adalia Armario Abella, was issued Emancipation Patent No. 147186 and Transfer Certificate of Title No. EP-219 for this portion. Despite this, Eutiquiano allowed his daughter, Maria Armario Villan, to occupy a portion of the lot. Eutiquiano and Abella executed a joint affidavit bequeathing the portion occupied by Villan's house to her. After Eutiquiano's death, his heirs executed an extrajudicial settlement awarding Villan a portion of Eutiquiano's lot, to be deducted from Adalia Abella's share. Abella also executed an affidavit confirming the transfer of 3,831 sq.m. of his lot to Villan. The City Agrarian Reform Officer issued a certification recognizing Villan's right over the 3,831 sq.m. identified as Lot No. 1713-B-2-A. Procedural History: Villan filed a complaint for cancellation of TCT No. EP-219 with the Regional Trial Court (RTC), which dismissed it for lack of jurisdiction, directing her to file with the Department of Agrarian Reform (DAR). Villan then filed a complaint for restoration and/or correction of entries in TCT No. EP-219 with the DAR Adjudication Board (DARAB) against Spouses Reynaldo and Adalia Abella. The Regional Agrarian Reform Adjudicator ruled in favor of Villan, directing Spouses Abella to turn over possession of the 3,831 sq.m. to Villan and ordering the cancellation/correction of TCT-EP-219. The DARAB affirmed this judgment. Spouses Abella appealed to the Court of Appeals (CA), which also affirmed the DARAB's decision. Adalia Abella, as the surviving spouse of Reynaldo Abella, filed a Petition for Review on Certiorari with the Supreme Court. The Petition: Petitioner Adalia Abella claims her husband was the rightful beneficiary of the excess land, evidenced by TCT No. EP-219. She argues her father-in-law handed the title to Abella without complaint, showing concurrence. She asserts Abella paid the amortizations and that Villan's claim is spurious. She claims the joint affidavit is void due to her lack of consent and that the property is community property. Petitioner also questions the DARAB's jurisdiction over the case and its authority to direct the transfer of a portion of the lot.
Issue(s)
Whether or not the Department of Agrarian Reform Adjudication Board (DARAB) had the requisite jurisdiction to take cognizance of respondent's petition for restoration and/or correction of entries in Transfer Certificate of Title No. EP-219. Whether or not the Court of Appeals erred in upholding the award in respondent's favor and directing petitioner to transfer a portion of Transfer Certificate of Title No. EP-219 to respondent.
Ruling
The Petition is DENIED. The Court affirmed the Court of Appeals' Decision which sustained the Department of Agrarian Reform Adjudication Board's Judgment directing the transfer of a portion of land covered by Transfer Certificate of Title No. EP-219 from Reynaldo Abella to Maria Armario Villan.
Ratio Decidendi
On the issue of DARAB's jurisdiction: The Court reiterated that the Department of Agrarian Reform (DAR), through the DARAB, is vested with primary and exclusive jurisdiction to determine and adjudicate agrarian reform matters and implement the Comprehensive Agrarian Reform Program (CARP) under Republic Act No. 6657. This jurisdiction extends to all matters involving the implementation of CARP, including disputes concerning the issuance, correction, and cancellation of Certificates of Land Ownership Award (CLOAs) and Emancipation Patents. The complaint for restoration and/or correction of entries in TCT No. EP-219 directly involved the implementation of CARP, specifically concerning the correct recipient of a portion of a lot awarded to a farmer-beneficiary. Therefore, the DARAB rightfully had jurisdiction over the case. The Court emphasized that even the issuance of an emancipation patent or a land title does not divest the DARAB of its jurisdiction over agrarian disputes, as these titles are merely evidence of transfer and can be subject to scrutiny if the underlying patent or award is void. The RTC's dismissal of Villan's initial complaint for lack of jurisdiction further validated the DARAB's competence. On the merits of the award to respondent: The Court found that the Court of Appeals did not err in upholding the award in respondent Villan's favor. The Court reiterated that in a Rule 45 petition, it is not a trier of facts, and factual findings of the CA, when supported by substantial evidence, are binding. Petitioner failed to establish any of the exceptions to this rule. The Court found substantial evidence supporting Villan's claim, including the joint affidavit of ownership between Eutiquiano and Reynaldo Abella, the extrajudicial partition executed by Eutiquiano's heirs, and Reynaldo Abella's own affidavit confirming the transfer of 3,831 sq.m. to Villan as part of her inheritance. These documents, along with the certification from the City Agrarian Reform Officer, demonstrated Eutiquiano's intent to bequeath a portion of the lot to his daughter, which was acknowledged by his family, including the petitioner. The Court noted that lands acquired by beneficiaries under CARP may only be transferred through hereditary succession, which was consistent with the evidence presented.
Main Doctrine
The Department of Agrarian Reform Adjudication Board (DARAB) has primary and exclusive jurisdiction over all matters involving the implementation of the Comprehensive Agrarian Reform Program (CARP), including disputes concerning the reallocation or transfer of farmlots awarded to farmer-beneficiaries, even after the issuance of an emancipation patent or land title. The issuance of a certificate of title does not divest the DARAB of its jurisdiction over issues hinging on the application of CARP.