The Supreme Court affirmed that the Department of Agrarian Reform Adjudication Board (DARAB) has primary jurisdiction over cases involving the annulment of land sales covered by the Comprehensive Agrarian Reform Program (CARP), particularly when tenancy rights are in dispute. This ruling clarifies that even if the parties involved are not direct tenants or landlords, DARAB’s jurisdiction prevails if the core issue concerns CARP implementation. The decision underscores the importance of resolving agrarian disputes within the specialized expertise of the DARAB, ensuring consistent application of agrarian reform laws and protecting the rights of tenant farmers and agrarian reform beneficiaries.

From Landowner Sale to Heir Dispute: Defining DARAB’s Reach

This case revolves around a dispute among heirs of Virginia P. Estrella, who was a beneficiary of Emancipation Patents (EPs) for several agricultural lands. After Virginia’s death, her heirs sought to partition the land. However, Spouses Teofilo and Teodora Carpio, also heirs, refused, claiming exclusive ownership of one parcel under Emancipation Patent No. 445229. They argued they had purchased it from the original landowner, Luis T. Bautista, and asserted tenancy rights. The other heirs filed a case for annulment of the sale, leading to a jurisdictional dispute that ultimately reached the Supreme Court.

The central legal question was whether the DARAB had jurisdiction over the case, given the claim of sale and the assertion of tenancy rights by one group of heirs against the others. The spouses argued that the regular courts, not the DARAB, should handle the matter, but the other heirs contended that the issue was intrinsically linked to the implementation of CARP. The Supreme Court sided with the heirs, emphasizing the DARAB’s mandate to resolve disputes arising from agrarian reform implementation.

The Court grounded its decision on Section 1, Rule II of the DARAB New Rules of Procedure, which explicitly grants the DARAB primary and exclusive jurisdiction over agrarian disputes involving CARP. This includes the annulment or cancellation of deeds of sale involving lands under the administration and disposition of the DAR or Land Bank of the Philippines (LBP), as well as cases involving the sale, alienation, or mortgage of agricultural lands under CARP. The Court highlighted that the key issue was the validity of the sale of agricultural land covered by CARP, making it a matter squarely within the DARAB’s competence.

The Supreme Court quoted its previous ruling in Department of Agrarian Reform v. Abdulwahid, emphasizing that when a case is merely an incident involving CARP implementation, jurisdiction remains with the DARAB, not the regular courts.

The Department of Agrarian Reform Adjudication Board (DARAB) is vested with primary and exclusive jurisdiction to determine and adjudicate agrarian reform matters, including all matters involving the implementation of the agrarian reform program. Thus, when a case is merely an incident involving the implementation of the Comprehensive Agrarian Reform Program (CARP), then jurisdiction remains with the DARAB, and not with the regular courts.

Furthermore, the Court stressed that jurisdiction is determined not only by the parties’ relationship but also by the nature of the issues in controversy. If the issues are intertwined with resolving a matter within the DARAB’s exclusive jurisdiction, the DARAB must handle the dispute.

[J]urisdiction should be determined by considering not only the status or relationship of the parties but also the nature of the issues or questions that is the subject of the controversy. Thus, if the issues between the parties are intertwined with the resolution of an issue within the exclusive jurisdiction of the DARAB, such dispute must be addressed and resolved by the DARAB.

In this case, the Court found that the allegations in the complaint clearly demonstrated that the final resolution depended on the validity of the sale of CARP-covered land, an issue directly under the DARAB’s purview. The Court considered the claim of tenancy rights and the validity of the sale, recognizing that these issues were integral to determining who was the rightful beneficiary of the land under CARP.

Petitioners also argued that they were the rightful tenants of the land and that the sale to them was valid. However, the Court dismissed this argument, stating that it involved a question of fact not reviewable in a petition for review on certiorari. The Court emphasized that its review is generally confined to errors of law, not a re-evaluation of evidence.

The Court cited the case of Diokno v. Cacdac, reiterating that its judicial review does not extend to re-examining the sufficiency of evidence upon which a tribunal based its determination.

Thus, only questions of law may be brought by the parties and passed upon by this Court in the exercise of its power to review. Also, judicial review by this Court does not extend to a reevaluation of the sufficiency of the evidence upon which the proper x x x tribunal has based its determination.

The DARAB had already made factual findings that Virginia P. Estrella was the recognized tenant, and the Emancipation Patents were issued to her accordingly. The Court deferred to these findings, which were affirmed by the Court of Appeals.

The Court underscored that findings of fact made by quasi-judicial bodies with expertise in specific matters are generally accorded respect and finality when affirmed by the Court of Appeals. This principle is rooted in the recognition that these bodies possess specialized knowledge and experience in their respective domains.

The Court referenced Reyes v. National Labor Relations Commission, highlighting that findings of fact of quasi-judicial bodies, when affirmed by the Court of Appeals, are conclusive on the Supreme Court, which is not a trier of facts.

Findings of fact of administrative agencies and quasi-judicial bodies, which have acquired expertise because their jurisdiction is confined to specific matters, are generally accorded not only respect, but finality when affirmed by the Court of Appeals. Such findings deserve full respect and, without justifiable reason, ought not to be altered, modified or reversed.

Ultimately, the Supreme Court found no compelling reason to deviate from the established rule that factual findings of an administrative agency, when affirmed by the Court of Appeals, are accorded not only respect but finality. This adherence to established principles underscores the importance of respecting the expertise of administrative bodies in their respective areas of competence.

In summary, the Supreme Court’s decision reaffirms the DARAB’s primary role in resolving agrarian disputes, particularly those involving the implementation of CARP. It clarifies that the DARAB’s jurisdiction extends to cases where the core issue is the validity of land transactions covered by CARP, even if other legal questions, such as tenancy rights, are also involved. The ruling reinforces the principle that factual findings of administrative bodies, when affirmed by the Court of Appeals, are generally conclusive and binding on the Supreme Court.

FAQs

What was the key issue in this case?	The key issue was whether the DARAB had jurisdiction over a dispute involving the annulment of a land sale covered by CARP, where tenancy rights were also claimed.
Who were the parties involved?	The parties involved were the heirs of Virginia P. Estrella, a CARP beneficiary, with some heirs (Spouses Carpio) claiming ownership through a sale from the original landowner.
What is an Emancipation Patent (EP)?	An Emancipation Patent is a title issued to tenant-farmers who have been awarded land under the agrarian reform program, signifying their ownership of the land they till.
What does CARP stand for?	CARP stands for the Comprehensive Agrarian Reform Program, which aims to redistribute agricultural lands to landless farmers and farmworkers.
Why is DARAB’s jurisdiction important in agrarian disputes?	DARAB’s jurisdiction is important because it ensures that agrarian disputes are resolved by a specialized body with expertise in agrarian reform laws and their implementation.
What was the Court’s ruling on the factual findings of DARAB?	The Court ruled that the factual findings of the DARAB, when affirmed by the Court of Appeals, are generally conclusive and binding on the Supreme Court.
Can the Supreme Court review questions of fact in a petition for review on certiorari?	Generally, the Supreme Court cannot review questions of fact in a petition for review on certiorari, as its review is limited to errors of law.
What is the practical implication of this ruling?	The practical implication is that disputes involving land sales under CARP, even with other issues involved, should be brought before the DARAB for resolution.

This case serves as a clear reminder of the DARAB’s crucial role in adjudicating agrarian disputes and upholding the principles of agrarian reform. It highlights the importance of respecting the expertise of administrative bodies and adhering to established legal principles in resolving complex land-related conflicts.

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: Spouses Teofilo Carpio and Teodora Carpio vs. Ana Sebastian, Vicenta Palao, Santos Estrella, and Vicenta Estrella, G.R. No. 166108, June 16, 2010