Union Bank of the Philippines v. Regional Agrarian Reform Officer
REITERATIONFacts
The Antecedents: Union Bank of the Philippines (Union Bank) was the registered owner of two parcels of land in Calamba, Laguna, covered by Transfer Certificate of Title (TCT) Nos. T-137846 and T-156610. Union Bank offered these lands to the Department of Agrarian Reform (DAR) through a Voluntary Offer to Sell (VOS) arrangement under the Comprehensive Agrarian Reform Program (CARP). After inspection, DAR and Land Bank of the Philippines (LBP) offered just compensation, which Union Bank did not agree with. Subsequently, the DAR began issuing Certificates of Land Ownership Award (CLOAs) to private respondents as agrarian reform beneficiaries for the land under TCT No. T-156610, and the land under TCT No. 137846 was transferred to the Republic of the Philippines. Union Bank later filed a "Motion to Withdraw Voluntary Offer To Sell On Property from CARP Coverage" and a letter request to the DAR to withdraw the VOS and to exempt the properties from CARP coverage, alleging that the properties had a slope exceeding 18% and were undeveloped, thus exempt under Section 10 of the Comprehensive Agrarian Reform Law (CARL). Procedural History: The DAR Secretary denied Union Bank's request for CARP exemption and VOS withdrawal, finding that Union Bank failed to prove by substantial evidence that the properties were both undeveloped and had a slope gradation of more than 18%, as the submitted maps were not certified by the Department of Environment and Natural Resources (DENR). The DAR Secretary's decision was affirmed by the Court of Appeals (CA) Fifteenth Division in CA-G.R. SP No. 114159. Separately, Union Bank filed petitions for cancellation of CLOAs with the Office of the Provincial Agrarian Reform Adjudicator (PARAD) of Laguna, which were dismissed without prejudice for being premature due to the pending CARP exemption request. The Department of Agrarian Reform Adjudication Board (DARAB) affirmed the PARAD's dismissal, which was further affirmed by the CA Fifteenth Division in CA-G.R. SP No. 114354. In another petition for cancellation of CLOAs, the PARAD and DARAB again dismissed the case for prematurity. The CA Special Twelfth Division, in CA-G.R. SP No. 116106, affirmed the dismissal, adding that the DARAB lacked jurisdiction due to the absence of a tenancy relationship between Union Bank and the agrarian reform beneficiaries. The Petition: Union Bank filed consolidated petitions for review on certiorari with the Supreme Court, docketed as G.R. Nos. 203330-31 and G.R. No. 200369. Union Bank assailed the dismissal of its petitions for cancellation of CLOAs, arguing that the DARAB is expressly granted quasi-judicial powers by Executive Order (EO) No. 229 and that the DAR Secretary was "effectively ousted" from jurisdiction. It insisted that the DARAB "cannot share jurisdiction" with the DAR Secretary on the validity of CLOA issuance. Union Bank also questioned the DAR Secretary's factual finding that the properties were not exempt from CARP, citing appraisal reports indicating an elevated slope of more than 18% and lack of irrigation.
Issue(s)
Whether the Department of Agrarian Reform Adjudication Board (DARAB) has jurisdiction over petitions for cancellation of Certificates of Land Ownership Award (CLOAs) involving parties who do not have a tenancy relationship. Whether the factual findings of the Secretary of Agrarian Reform can be questioned in a petition for review on certiorari under Rule 45.
Ruling
The petitions are DENIED. The Decision dated November 18, 2011 and Resolution dated January 27, 2012 of the Court of Appeals-Special Twelfth Division in CA-G.R. SP No. 116106, and the Decision dated October 21, 2011 and Resolution dated August 30, 2012 of the Court of Appeals-Fifteenth Division in CA-G.R. SP Nos. 114159 and 114354 are AFFIRMED.
Ratio Decidendi
On Issue 1: The Supreme Court held that the jurisdiction of the Provincial Agrarian Reform Adjudicator (PARAD) and the Department of Agrarian Reform Adjudication Board (DARAB) is limited to "agrarian disputes," as defined in Section 3(d) of the Comprehensive Agrarian Reform Law (CARL). For the PARAD and DARAB to acquire jurisdiction, there must be a prima facie showing of a tenurial arrangement or tenancy relationship between the parties, which includes essential requisites such as the parties being landowner and tenant, agricultural land, consent, agricultural production purpose, personal cultivation, and sharing of harvests. In this case, Union Bank's petitions for cancellation of Certificates of Land Ownership Award (CLOAs) did not allege any tenurial or agrarian relations, and the Court found no evidence of a tenancy relationship between Union Bank and the agrarian reform beneficiaries. Therefore, the PARAD and DARAB lacked jurisdiction over the petitions. The Court clarified that while Section 17 of Executive Order (EO) No. 229 and Section 50 of the CARL vested primary jurisdiction in the Department of Agrarian Reform (DAR) over agrarian reform matters, EO No. 129-A effectively split this jurisdiction, assigning agrarian disputes to the DARAB and administrative implementation to the DAR regional offices. Citing Valcurza v. Tamparong, Jr., the Court reiterated that cancellation of CLOAs involving parties who are not agricultural tenants falls under the DAR's administrative implementation jurisdiction, not the DARAB's. On Issue 2: The Supreme Court affirmed that only questions of law may be raised in a petition for review on certiorari under Rule 45, as the Supreme Court is not a trier of facts. It is not the Court's function to analyze or weigh evidence anew. The Court reiterated the doctrine that factual findings of administrative agencies are generally accorded respect and even finality, especially when these findings are affirmed by the Court of Appeals. Union Bank's claim for exemption from the Comprehensive Agrarian Reform Program (CARP) based on the 18% slope rule under Section 10 of the CARL requires that the land must have a gradation slope of 18% or more and must be undeveloped. While Union Bank claimed the properties exceeded 18% slope and were not irrigated, the Department of Agrarian Reform (DAR) Secretary, in weighing the evidence, found that Union Bank failed to prove both conditions, noting the Municipal Agrarian Reform Officer's (MARO) report of agricultural development. The Court found no clear showing that the DAR Secretary acted in grave abuse of discretion, thus upholding his exercise of discretion. The Court also noted that Union Bank's arguments regarding non-payment of just compensation and procedural irregularities in CLOA issuance were raised for the first time on appeal, which is prohibited by the fundamental rule of fair play and due process.
Main Doctrine
The Department of Agrarian Reform Adjudication Board (DARAB) has jurisdiction over cases involving the cancellation of registered Certificates of Land Ownership Award (CLOAs) only when such cases relate to an agrarian dispute between landowners and tenants. Conversely, cases concerning the cancellation of CLOAs that involve parties who are not agricultural tenants or lessees, and are related to the administrative implementation of agrarian reform laws, rules, and regulations, fall under the exclusive jurisdiction of the Department of Agrarian Reform (DAR) Secretary. Furthermore, the factual findings of administrative agencies, particularly the DAR Secretary, are generally accorded respect and finality by the Supreme Court, especially when affirmed by the Court of Appeals, as the Supreme Court is not a trier of facts and will only interfere upon a clear showing of grave abuse of discretion.