In Concha v. Rubio, the Supreme Court affirmed that the Department of Agrarian Reform (DAR) holds exclusive jurisdiction in identifying and selecting qualified farmer-beneficiaries under the Comprehensive Agrarian Reform Program (CARP). This ruling clarifies that the Department of Agrarian Reform Adjudication Board (DARAB) overstepped its authority when it intervened in beneficiary selection, an administrative function solely entrusted to the DAR Secretary. The decision reinforces the principle that administrative agencies should operate within their legally defined boundaries, ensuring the proper implementation of agrarian reform laws.

Land Rights Crossroads: Who Decides the Fate of Farmer-Beneficiaries?

The case revolves around a dispute over a portion of land covered by Transfer Certificates of Title Nos. T-140494, T-140492, and T-140491, involving petitioners Romanita Concha, et al., and respondents Paulino Rubio, et al. The core issue is determining which group is qualified to be beneficiaries under the Comprehensive Agrarian Reform Program (CARP). The land, initially under private ownership, was subjected to the Compulsory Acquisition Scheme of CARP, leading to a conflict over beneficiary selection. This conflict reached the courts after the respondents, claiming to be the rightful tenants, challenged the petitioners’ inclusion as beneficiaries. The registered owners had entered into a joint project for land development before the dispute escalated. The landowners’ application for conversion was approved by the DAR, under the condition that the remaining hectares would be covered by CARP and distributed to qualified beneficiaries.

The roots of the dispute lie in conflicting claims over tenancy rights and beneficiary status. Respondents asserted their rights as tenants, alleging they had not relinquished their claims despite receiving monetary awards from the landowners. Petitioners, on the other hand, were identified as qualified farmer-beneficiaries, leading to the issuance of Certificates of Land Ownership Awards (CLOAs) in their favor. Respondents questioned the validity of these CLOAs, leading to legal battles that spanned from the Provincial Agrarian Reform Adjudicator (PARAD) to the Court of Appeals (CA). The PARAD initially dismissed the case, stating that respondents had waived their rights and that the selection of beneficiaries was an administrative matter for the DAR. The DARAB, however, reversed this decision, favoring the respondents and ordering the cancellation of the CLOAs issued to the petitioners.

The CA initially ruled in favor of the petitioners, upholding the titles issued in their favor, but later reversed its decision upon reconsideration, reinstating the DARAB’s decision. This vacillation by the CA set the stage for the Supreme Court to weigh in on the matter. The Supreme Court, in its analysis, focused on whether the DARAB possessed the jurisdiction to resolve the issue of identifying and selecting qualified farmer-beneficiaries. According to the petitioners, this matter fell under the administrative functions of the DAR Secretary, thus placing it beyond DARAB’s authority. This contention formed the crux of the Supreme Court’s examination and ultimately shaped the outcome of the case.

The Supreme Court anchored its decision on the principle that the identification and selection of CARP beneficiaries are administrative functions falling exclusively within the jurisdiction of the DAR Secretary. Citing Lercana v. Jalandoni, the Court emphasized that these matters involve the administrative implementation of CARP and are beyond the purview of the DARAB. Further, the Court referenced Sta. Rosa Realty Development Corporation v. Amante to highlight the DAR Secretary’s vested authority in beneficiary selection. The Court quoted Section 15 of R.A. No. 6657, which tasks the DAR, in coordination with the Barangay Agrarian Reform Committee (BARC), with registering qualified beneficiaries of CARP, underscoring the administrative nature of this process.

SECTION 15. Registration of Beneficiaries. — The DAR in coordination with the Barangay Agrarian Reform Committee (BARC) as organized in this Act, shall register all agricultural lessees, tenants and farm workers who are qualified to be beneficiaries of the CARP.

Building on this principle, the Court scrutinized the DARAB Revised Rules, emphasizing that matters strictly involving the administrative implementation of CARP are the exclusive prerogative of the DAR Secretary. Rule II of the DARAB Revised Rules provides the scope of the board’s jurisdiction but explicitly excludes matters involving administrative implementation. The administrative function of the DAR is evident in Administrative Order No. 06-00, which specifies that the DAR Secretary has exclusive jurisdiction over the identification, qualification, or disqualification of potential farmer-beneficiaries. Section 2 of the said rules details the cases falling within the DAR Secretary’s exclusive jurisdiction, reinforcing the Court’s view that the DARAB had overstepped its boundaries.

The Court observed that the PARAD was correct in its initial assessment that it lacked jurisdiction to resolve the dispute. The Court quoted the PARAD’s decision, which stated that no other agency is empowered to select farmer-beneficiaries except the DAR. Despite the PARAD’s clear recognition of its jurisdictional limitations, the DARAB granted affirmative relief to the respondents without addressing the critical issue of jurisdiction. This oversight, according to the Court, was a significant misstep. While acknowledging that the petitioners did not raise the jurisdictional issue before the DARAB, the Court maintained that this did not justify the DARAB’s action, particularly given the PARAD’s explicit discussion of its lack of jurisdiction. The same reasoning applied to the CA’s decision, which failed to address the jurisdictional impediment despite the petitioners raising the issue in their petition.

The Supreme Court also addressed the circumstances surrounding the respondents’ initial waivers of their rights as tenants and farmer-beneficiaries. While recognizing the potential reluctance of long-term tenants to relinquish their land rights, as highlighted in Torres v. Ventura, the Court distinguished the case at bar. The Court emphasized the administrative prerogative of the DAR to identify and select agrarian reform beneficiaries, referencing Department of Agrarian Reform v. Department of Education, Culture and Sports. This prerogative, according to the Court, should not be easily substituted by judicial determination unless there is a grave abuse of discretion by the administrative agency. The Court, therefore, accorded respect to the Municipal Agrarian Reform Officer’s (MARO) decision not to include the respondents as farmer-beneficiaries, citing the MARO’s Affidavit explaining the reasons for their exclusion.

The MARO’s Affidavit detailed how the respondents had refused to cooperate with the documentation process, received disturbance compensation and lots from the landowners, and executed sworn statements waiving their rights. The Court found that this declaration strengthened the earlier Decision of the PARAD, which ruled that the waivers executed by the respondents were valid and binding. The Court also noted the PARAD’s observation that the respondents were motivated by greed when they sought to repudiate their sworn statements. The PARAD viewed their actions as an attempt to enrich themselves unfairly at the expense of the petitioners. The respondents’ allegation that they were the true tenants was deemed a matter within the exclusive jurisdiction of the DAR.

The Court clarified that being a tenant of a land covered by CARP does not automatically entitle one to be a farmer-beneficiary. Section 22 of Republic Act No. 6657 provides an order of priority for qualified farmer beneficiaries, which the MARO or Provincial Agrarian Reform Officer (PARO) must follow. The Court reiterated that any individual contesting the selection of beneficiaries should avail themselves of administrative remedies within the DAR, not through the DARAB. The DARAB’s role is not to review or reverse the administrative findings of the DAR. Instead, it should defer to the DAR’s expertise in identifying and selecting beneficiaries, as illustrated in Lercana. This deference is now codified in Rule II of the DARAB’s 2003 Rules of Procedure, which allows for the referral of cases involving prejudicial issues related to agrarian law implementation to the Office of the Secretary (OSEC).

The Court emphasized that while findings of administrative agencies like the DARAB are accorded respect and finality due to their expertise, it is crucial to maintain jurisdictional boundaries set by law. In this case, the DARAB overstepped its legal boundaries by taking cognizance of the dispute and deciding who should be declared the farmer-beneficiaries. The CA, therefore, erred in affirming the DARAB’s decision, which was rendered in excess of jurisdiction. The decision underscores the necessity of respecting the specific roles and expertise of administrative agencies within their legally defined scopes of authority.

FAQs

What was the key issue in this case?	The central issue was whether the Department of Agrarian Reform Adjudication Board (DARAB) had jurisdiction to decide on the identification and selection of qualified farmer-beneficiaries under the Comprehensive Agrarian Reform Program (CARP).
Who has the authority to identify CARP beneficiaries?	The Department of Agrarian Reform (DAR) Secretary has the exclusive authority to identify, qualify, or disqualify potential farmer-beneficiaries under the Comprehensive Agrarian Reform Program (CARP). This function is administrative in nature.
What was the basis for the Supreme Court’s decision?	The Supreme Court based its decision on the principle that the identification and selection of CARP beneficiaries are administrative functions that fall exclusively within the jurisdiction of the DAR Secretary, not the DARAB.
What did the PARAD initially rule?	The Provincial Agrarian Reform Adjudicator (PARAD) initially dismissed the case, stating that the respondents had waived their rights as tenants and that the selection of beneficiaries was an administrative matter for the DAR.
What was the MARO’s role in this case?	The Municipal Agrarian Reform Officer (MARO) is responsible for screening and selecting potential agrarian beneficiaries. In this case, the MARO’s decision not to include the respondents as farmer-beneficiaries was given deference by the Supreme Court.
Can a tenant automatically become a CARP beneficiary?	No, a tenant of a land covered by CARP is not automatically entitled to be a farmer-beneficiary. Section 22 of Republic Act No. 6657 provides an order of priority of qualified farmer-beneficiaries.
What should individuals do if they disagree with the selection of beneficiaries?	Individuals who disagree with the selection of beneficiaries should avail themselves of administrative remedies under the DAR, such as filing a protest with the MARO or PARO, rather than going through the DARAB.
What is the significance of Administrative Order No. 06-00?	Administrative Order No. 06-00 provides the Rules of Procedure for Agrarian Law Implementation Cases, emphasizing that the DAR Secretary has exclusive jurisdiction over the identification, qualification, or disqualification of potential farmer-beneficiaries.

The Supreme Court’s decision in Concha v. Rubio serves as a crucial reminder of the importance of adhering to jurisdictional boundaries within administrative agencies. By reinforcing the DAR’s exclusive authority in beneficiary selection, the Court ensures the consistent and effective implementation of agrarian reform laws, preventing potential overreach by bodies like the DARAB. This clarification benefits both potential beneficiaries and landowners by providing a clear framework for resolving disputes related to land distribution under CARP.

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: Romanita Concha, et al. vs. Paulino Rubio, et al., G.R. No. 162446, March 29, 2010