In Hon. Antonio M. Nuesa vs. Hon. Court of Appeals, the Supreme Court clarified the jurisdictional boundaries between the Department of Agrarian Reform (DAR) and the Department of Agrarian Reform Adjudication Board (DARAB). The Court ruled that DARAB exceeded its jurisdiction by overturning the DAR Regional Director’s decision regarding the cancellation of an Order of Award for land in the Buenavista Estate. This decision reaffirms that matters concerning the administrative implementation of agrarian reform, particularly the issuance or cancellation of land transfer certificates, fall under the exclusive purview of the DAR, not DARAB, unless a clear agrarian dispute exists.

Buenavista Estate Battle: Who Decides Land Rights, DAR or DARAB?

The case revolves around conflicting claims to Lots 1932 and 1904 of the Buenavista Estate. In 1972, Jose Verdillo received an Order of Award for these lots, subject to certain cultivation and development conditions. Twenty-one years later, Verdillo applied to purchase the lots, claiming compliance with the conditions. Restituto Rivera protested, asserting his own possession and cultivation of the land. The DAR Regional Office investigation revealed that individuals other than Verdillo had been in possession/cultivation of the lots. Consequently, the Regional Director cancelled Verdillo’s Order of Award, declaring the lots open for disposition to qualified applicants and considering Rivera’s application.

Verdillo then filed a petition with the Provincial Adjudication Board (PAB) seeking annulment of the Regional Director’s order. Instead of filing an answer, the petitioners sought dismissal arguing that the proper avenue was appeal to the Secretary of the DAR, not a petition to the PAB. DARAB ruled against this, reversing the Regional Director’s order. This decision was affirmed by the DARAB and eventually the Court of Appeals. The main legal question before the Supreme Court was whether the DARAB acted within its jurisdiction in taking cognizance of the dispute and reversing the DAR Regional Director’s decision.

The Supreme Court emphasized the distinct roles of DAR and DARAB. **Presidential Decree (P.D.) 946** grants the DAR Secretary exclusive jurisdiction over matters involving the administrative implementation of land transfer under P.D. No. 27, including the issuance, recall, or cancellation of land transfer certificates. Building on this principle, the Court underscored that DARAB’s jurisdiction is limited to “agrarian disputes,” as defined under **Section 3(d) of R.A. 6657 (CARP Law)**.

“(d) …any controversy relating to tenurial arrangements, whether leasehold, tenancy, stewardship or otherwise over lands devoted to agriculture, including disputes concerning farmworkers associations or representation of persons in negotiating, fixing, maintaining, changing or seeking to arrange terms or conditions of such tenurial arrangements.  It includes any controversy relating to compensation of lands acquired under this Act and other terms and conditions of transfer of ownership from landowners to farmworkers, tenants and other agrarian reform beneficiaries, whether the disputants stand in the proximate relation of farm operator and beneficiary, landowner and tenant, or lessor and lessee.”

In this specific instance, no tenurial, leasehold, or agrarian relationship existed between Rivera and Verdillo. Since no tenurial relationship exists between Rivera and Verdillo, the DARAB should not have taken cognizance of Verdillo’s petition. Administrative Order No. 3, Series of 1990 prioritizes distribution of land to actual occupant/tillers. Thus, if Verdillo wasn’t the actual tiller, it further strengthened DAR’s authority to address violations of the terms of the Order of Award and to promote agrarian reform.

Therefore, the Supreme Court concluded that the DARAB exceeded its authority by reversing the DAR Regional Director’s decision and resolving the case on its merits. While recognizing the expertise of administrative agencies within their specific domains, the Court asserted the need to respect jurisdictional boundaries. In the final ruling, the Court granted the petition, reversing the Court of Appeals’ decision and reinstating the DAR Regional Director’s order in favor of Restituto Rivera.

FAQs

What was the key issue in this case?	The key issue was whether the DARAB had jurisdiction over the dispute between Jose Verdillo and Restituto Rivera regarding the Order of Award for land in the Buenavista Estate.
What did the DAR Regional Director decide?	The DAR Regional Director cancelled Jose Verdillo’s Order of Award due to non-compliance with its terms and opened the land for disposition to qualified applicants, including Restituto Rivera.
What was DARAB’s role in this case?	DARAB initially reversed the DAR Regional Director’s decision, but the Supreme Court later determined that DARAB acted outside its jurisdiction.
What is an “agrarian dispute”?	An “agrarian dispute” is a controversy relating to tenurial arrangements over agricultural lands or the terms of ownership transfer to farmworkers and tenants.
Why did the Supreme Court rule in favor of the petitioners?	The Supreme Court ruled that DARAB had no jurisdiction over the case because no tenurial or agrarian relationship existed between the parties.
What is the significance of Administrative Order No. 3?	Administrative Order No. 3 emphasizes distributing land to actual occupants/tillers, which supported the DAR Regional Director’s decision.
Who has jurisdiction over administrative implementation of land transfer?	The Secretary of the Department of Agrarian Reform has exclusive jurisdiction over matters involving the administrative implementation of land transfer.
What was the final outcome of the case?	The Supreme Court reversed the Court of Appeals’ decision and reinstated the DAR Regional Director’s order in favor of Restituto Rivera.

This case clarifies the scope of authority of DAR and DARAB in agrarian reform matters, emphasizing the importance of respecting jurisdictional boundaries between administrative agencies. Future disputes need to be evaluated based on these distinctions to avoid jurisdictional overreach.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Hon. Antonio M. Nuesa vs. Hon. Court of Appeals, G.R. No. 132048, March 06, 2002