The Supreme Court’s decision in Dao-ayan v. DARAB clarifies the importance of adhering to procedural rules in agrarian reform cases. The Court ruled that failure to appeal a decision of the Department of Agrarian Reform (DAR) within the prescribed period renders the decision final and executory. This means that parties who do not take timely action to challenge DAR decisions risk losing their rights. The ruling emphasizes the need for agrarian reform beneficiaries to be vigilant and proactive in protecting their interests within the legal framework of the Comprehensive Agrarian Reform Program (CARP).

Land Disputes: When Does the DARAB’s Authority Begin?

This case revolves around a dispute over land located in Kahaponan, Valencia City, Bukidnon, which was placed under the Comprehensive Agrarian Reform Program (CARP). Mariano Dao-ayan and his son, Marjun Dao-ayan, filed a complaint seeking the annulment and cancellation of Certificate of Land Ownership Award (CLOA) No. 00371923 and TCT No. AT-9035, which had been awarded to Araneta Landless Agrarian Reform Farmers Association (ALARFA). The central legal question is whether the Department of Agrarian Reform Adjudication Board (DARAB) had jurisdiction over the case, and whether the decision of the DAR disqualifying the Dao-ayans as beneficiaries had become final and executory.

The seeds of the controversy were sown when Marjun Dao-ayan initially applied to be a farmer-beneficiary but was later delisted. ALARFA then filed a petition to disqualify Mariano Dao-ayan, arguing that he already possessed substantial real properties, making him ineligible under CARP. The DAR Regional Director sided with ALARFA, disqualifying Mariano because he was already a beneficiary of land under Presidential Decree No. 27. Subsequently, CLOA No. 00371923 was issued to ALARFA, leading to the issuance of TCT No. AT-9035 in their name.

Reacting to these developments, the Dao-ayans sought to stay the execution of the CLOA award, alleging they were not properly notified of the disqualification proceedings. Undeterred, the Provincial Agrarian Reform Officer (PARO) issued an Installation Order, directing ALARFA’s installation on the land and ordering the Dao-ayans to vacate. This prompted the Dao-ayans to file their complaint for annulment and cancellation of ALARFA’s CLOA, setting the stage for a legal battle that would ultimately reach the Supreme Court.

The DARAB Regional Agrarian Reform Adjudicator dismissed the Dao-ayans’ complaint, reasoning that the DAR had the authority to determine farmer-beneficiaries. The adjudicator stated that the challenge to the DAR Regional Director’s decision should have been raised with the DAR Secretary. The DARAB emphasized that it lacked the authority to determine CARP beneficiaries. Furthermore, the DARAB stated:

[T]he matter of identification of farmer-beneficiaries had in fact been finally determined by the DAR…both the law and the DARAB procedures deny this Board the authority to determine the identification and qualification of would be CARP beneficiaries. It is an undertaking assigned to the DAR as an administrative agency, and where its resolutions and orders are assailed, the same must be ventilated according to hierarchical ladder up to the DAR Secretary.

The Court of Appeals upheld the DARAB’s decision, emphasizing that the Regional Director’s resolution had become final and executory because the Dao-ayans failed to appeal it to the Office of the Secretary of Agrarian Reform. The appellate court pointed to Section 22 of Administrative Order No. 6, Series of 2000, which explicitly states that decisions of the Regional Director become final after 15 days if no appeal is perfected. The Supreme Court, in its analysis, addressed two critical issues: the DARAB’s jurisdiction over annulment of registered CLOAs and the finality of the DAR Regional Director’s decision disqualifying the petitioners.

The Court reiterated that jurisdiction over the subject matter is determined by law. Republic Act No. 6657, also known as the Comprehensive Agrarian Reform Law of 1988, grants the DAR primary jurisdiction over agrarian reform matters and quasi-judicial powers. Section 50 of R.A. 6657 specifically vests the DAR with the power to adjudicate agrarian reform matters.

SEC. 50. Quasi-Judicial Powers of the DAR. – The DAR is hereby vested with primary jurisdiction to determine and adjudicate agrarian reform matters and shall have exclusive original jurisdiction over all matters involving the implementation of agrarian reform, except those falling under the exclusive jurisdiction of the Department of Agriculture (DA) and the Department of Environment and Natural Resources (DENR).

To govern proceedings before the DARAB, the DAR issued rules in accordance with its rule-making power under Section 49 of R.A. 6657. Given that the Dao-ayans filed their complaint on June 22, 1998, the 1994 DARAB Rules of Procedure apply.

Section 1, Rule II of the 1994 DARAB Rules defines the scope of the DARAB’s exclusive original jurisdiction. Pertinently, it includes cases involving the issuance, correction, and cancellation of Certificates of Land Ownership Award (CLOAs) and Emancipation Patents (EPs) that are registered with the Land Registration Authority. This is in contrast to matters involving the administrative implementation of R.A. No. 6657, which fall under the exclusive purview of the DAR Secretary.

The Court then referenced Section 2 of DAR Administrative Order No. 06-00, which enumerates the cases under the DAR Secretary’s exclusive jurisdiction. These include the classification and identification of landholdings for CARP coverage, identification of potential farmer-beneficiaries, and the issuance, recall, or cancellation of CLTs and CARP Beneficiary Certificates in cases outside the purview of P.D. No. 816, specifically EPs or CLOAs not yet registered with the Register of Deeds.

The Supreme Court has previously addressed the division of jurisdiction between the DAR and DARAB in Padunan v. DARAB. The Court clarified that cases involving the issuance, recall, or cancellation of CLOAs or EPs are within the jurisdiction of the DAR before registration with the Register of Deeds. Once these documents are registered, jurisdiction shifts to the DARAB.

Applying these principles to the case at hand, the Supreme Court concluded that the DARAB correctly assumed jurisdiction because the Dao-ayans’ complaint sought the cancellation of a CLOA that had already been registered.

Turning to the second issue, the Court of Appeals had relied on Section 22 of DAR Administrative Order No. 06-00, Series of 2000, to conclude that the DAR’s decision disqualifying the Dao-ayans had become final due to their failure to appeal within 15 days. The Supreme Court, however, noted that this administrative order was not applicable because all relevant events occurred before its issuance in 2000.

Since there was no specific administrative issuance addressing the finality of decisions by DAR Regional Directors at the time, the Court turned to the Administrative Code of 1987. Section 15 of the Administrative Code states that agency decisions become final 15 days after receipt by the adversely affected party, unless an administrative appeal or judicial review is perfected.

SEC. 15. Finality of Order. – The decision of the agency shall become final and executory fifteen (15) days after the receipt of a copy thereof by the party adversely affected unless within that period an administrative appeal or judicial review, if proper, has been perfected. One motion for reconsideration may be filed, which shall suspend the running of the said period.

The Court emphasized that the records lacked proof that the Dao-ayans had received notice of the proceedings before the DAR Regional Director. Therefore, the 15-day period began either on October 28, 1997, when the CLOA was registered (considered constructive notice), or on December 12, 1997, when the Dao-ayans filed a motion to stay execution. In either scenario, the Dao-ayans’ failure to appeal within 15 days meant that the DAR Regional Director’s resolution had become final and executory before they filed their complaint on June 22, 1998.

FAQs

What was the key issue in this case?	The central issue was whether the DARAB had jurisdiction to hear the case and whether the DAR Regional Director’s decision disqualifying the petitioners had become final and unappealable.
What is a CLOA?	CLOA stands for Certificate of Land Ownership Award. It is a title document issued to agrarian reform beneficiaries, granting them ownership of the land they till.
When does the DARAB have jurisdiction over CLOA disputes?	The DARAB has jurisdiction over cases involving the issuance, correction, and cancellation of CLOAs that have already been registered with the Land Registration Authority.
When does the DAR Secretary have jurisdiction over CLOA disputes?	The DAR Secretary has jurisdiction over cases involving the issuance, recall, or cancellation of CLOAs that have not yet been registered with the Register of Deeds.
What is the prescriptive period for appealing a DAR Regional Director’s decision?	According to the Administrative Code of 1987, the prescriptive period for appealing a DAR Regional Director’s decision is fifteen (15) days from receipt of a copy of the decision.
What happens if a party fails to appeal a DAR decision within the prescribed period?	If a party fails to appeal a DAR decision within the prescribed period, the decision becomes final and executory, meaning it can no longer be challenged.
What is constructive notice in land registration?	Constructive notice means that the registration of a document with the Register of Deeds serves as notice to the whole world of the existence of that document and its contents.
Why was the Court of Appeals’ reliance on DAR Administrative Order No. 06-00, Series of 2000, incorrect?	The Court of Appeals’ reliance was incorrect because all the events in question occurred before the issuance of Administrative Order No. 06-00, Series of 2000, meaning it could not be retroactively applied.

This case underscores the importance of adhering to procedural rules and timelines in agrarian reform matters. Landowners and potential beneficiaries must be aware of their rights and obligations, and they must take timely action to protect their interests. Failure to do so can result in the loss of valuable rights and opportunities.

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: Mariano Dao-ayan and Marjun Dao-ayan, vs. The Department of Agrarian Reform Adjudication Board (DARAB), G.R. No. 172109, August 29, 2007