Lorenzo v. Libunao
REITERATIONFacts
The Antecedents: This case originated from an Amended Complaint filed by petitioners Adriano S. Lorenzo, Sr., Jose D. Flores III, and Carlos S. Flores against respondents Dominador M. Libunao, Evagrio S. Libunao, Noe S. Libunao, and Mayo S. Libunao. The dispute concerns a nine-hectare portion of agricultural riceland known as the Patricio Pineda Estate. Petitioners claimed they and their predecessors-in-interest had been in possession of the land since 1978 and 1994, respectively, and alleged that respondents fraudulently secured emancipation patents and titles to the land. Respondents denied the fraud allegations, asserting they were duly identified as qualified farmer-beneficiaries by the Department of Agrarian Reform (DAR) and had been in actual possession of their respective landholdings. Procedural History: The Provincial Agrarian Reform Adjudicator (PARAD) dismissed the petitioners' complaint on January 27, 2009, affirming the validity of the respondents' emancipation patents and titles, finding no convincing evidence to contradict the DAR's administrative identification of respondents as beneficiaries. The Department of Agrarian Reform Adjudication Board (DARAB) initially affirmed the PARAD's decision on June 22, 2018. However, a subsequent DARAB Resolution on October 28, 2019, denied petitioners' motion for reconsideration, stating that jurisdiction over cancellation of titles issued under agrarian reform programs had been transferred to the DAR Secretary. The Court of Appeals (CA) affirmed the DARAB's lack of jurisdiction in its Decision dated June 30, 2021, and Resolution dated May 24, 2022, noting that Republic Act No. 9700, which transferred this jurisdiction, was already in effect when petitioners filed their appeal. 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 raise issues concerning whether the lower tribunals erred in appreciating their evidence, who between the parties is qualified as a beneficiary, and whether the emancipation patents and titles issued to respondents could be cancelled. Essentially, petitioners argue that the PARAD erred in affirming the emancipation patents and titles despite their alleged continuous possession of the subject land. The Supreme Court, however, emphasizes that a Rule 45 petition is limited to errors of law, not fact, and that the issue of possession requires factual re-evaluation. Furthermore, the Court notes that under RA 9700, the DAR Secretary now has exclusive original jurisdiction over such cancellation cases, and petitioners should have directed their claim to that office, rendering their petition premature.
Issue(s)
Whether the Court of Appeals, PARAD, and DARAB erred in not appreciating the evidence of the petitioners, and whether the DARAB had jurisdiction over the case. Who between the petitioners and respondents are qualified to be beneficiaries of the land in question. Whether the emancipation patents and titles issued to respondents could be cancelled, and the proper venue for resolving this issue.
Ruling
The petition is denied for lack of merit. The Decision dated June 30, 2021, and the Resolution dated May 24, 2022, of the Court of Appeals in CA-G.R. SP No. 164049 are affirmed.
Ratio Decidendi
On the jurisdiction of the DARAB and the effect of RA 9700: The Court affirmed the CA's ruling that the DARAB correctly divested itself of jurisdiction. Section 9 of RA 9700, amending Section 24 of RA 6657, explicitly states that all cases involving the cancellation of registered emancipation patents, certificates of land ownership award, and other titles issued under any agrarian reform program are within the exclusive and original jurisdiction of the Secretary of the DAR. The CA correctly noted that at the time petitioners filed their appeal with the DARAB on November 20, 2009, RA 9700 was already in force, divesting the DARAB of jurisdiction over such cases. Therefore, the CA committed no reversible error in denying the petition for review and ruling that the DARAB lacked jurisdiction to resolve petitioners' appeal. On determining qualified beneficiaries: The DAR Secretary, not the DARAB, has the authority to probe the validity of the issuance of the emancipation patents and titles and determine the qualification of farmer-beneficiaries. On the scope of review under Rule 45 and the doctrine of primary jurisdiction: The Court reiterated that a petition for review on certiorari under Rule 45 of the Rules of Court is confined to reviewing errors of law, not of fact. Petitioners were essentially asking the Court to re-evaluate their evidence to determine who actually possessed the subject land, which falls outside the scope of a Rule 45 review. While exceptions exist for reviewing factual findings, none were present in this case. The Court emphasized that the doctrine of primary jurisdiction requires that if a case requires the expertise of an administrative body, relief must first be obtained from that body before resorting to courts. Following the enactment of RA 9700, petitioners should have directed their appeal or filed a new case before the DAR Secretary, who possesses the expertise to resolve the issue of cancellation of patents and titles. Thus, petitioners' premature invocation of judicial powers was fatal to their cause.
Main Doctrine
The exclusive and original jurisdiction to resolve cases involving the cancellation of registered emancipation patents, certificates of land ownership award, and other titles issued under any agrarian reform program is vested in the Secretary of the Department of Agrarian Reform (DAR), as amended by Republic Act No. 9700.