The Supreme Court ruled that the Department of Agrarian Reform Adjudication Board (DARAB) and its subordinate Provincial Agrarian Reform Adjudicator (PARAD) lack jurisdiction over land disputes where no tenurial or agrarian relationship exists between the parties. This means that disputes concerning land covered by agrarian reform but not involving tenants, leaseholders, or other agrarian beneficiaries fall outside the DARAB’s authority. The decision emphasizes that DARAB’s jurisdiction is strictly limited to agrarian disputes and matters arising from the implementation of agrarian laws, safeguarding property rights beyond the scope of agrarian relationships.

Beyond the Farm: When Land Disputes Stray from Agrarian Roots

The case of Heirs of Candido Del Rosario and Heirs of Gil Del Rosario vs. Monica Del Rosario arose from a dispute over a parcel of land in Bulacan originally tenanted by the spouses Jose Del Rosario and Florentina De Guzman. After their death, their children, Monica, Candido, and Gil, became involved. Monica obtained an Emancipation Patent (EP) over the land, leading to a disagreement with her brothers’ heirs regarding the land’s partition. The heirs of Candido and Gil sought to amend Monica’s title, claiming an agreement existed where Monica would cede one-third of the land to Gil after the EP was issued. Monica, however, refused, leading to a legal battle that questioned whether the DARAB had jurisdiction over the dispute given the absence of a direct agrarian relationship between the siblings.

The petitioners argued that the PARAD and DARAB had jurisdiction because the case involved determining the rightful beneficiary of the land under agrarian reform laws. Monica countered that no tenancy relationship existed, thus removing the case from DARAB’s jurisdiction. The PARAD initially ruled in favor of the petitioners, ordering the partition of the land. However, the DARAB reversed this decision, stating that the agreement between Monica and Gil was void as it violated the prohibition against transferring land granted to farmer-beneficiaries, except through hereditary succession or to the government. The Court of Appeals (CA) ultimately denied the petition for review, agreeing that the PARAD and DARAB lacked jurisdiction due to the absence of an agrarian dispute or tenancy relations.

The Supreme Court analyzed the jurisdiction of the PARAD and DARAB, emphasizing that it is limited to agrarian disputes and matters or incidents involving the implementation of the Comprehensive Agrarian Reform Program (CARP). The Court cited Section 1, Rule II of the 1994 DARAB Rules of Procedure, which outlines the Board’s primary and exclusive jurisdiction over “all agrarian disputes involving the implementation of the Comprehensive Agrarian Reform Program (CARP) under Republic Act No. 6657, Executive Order Nos. 228, and 129-A, Republic Act No. 3844 as amended by Republic Act No. 6389, Presidential Decree No. 27 and other agrarian laws and their implementing rules and regulations.” This jurisdiction extends to cases involving the rights and obligations of persons engaged in the management, cultivation, and use of agricultural lands covered by CARP, as well as the issuance, correction, and cancellation of Certificates of Land Ownership Award (CLOAs) and Emancipation Patents (EPs).

However, the Court noted that an agrarian dispute, as defined in Section 3(d) of R.A. No. 6657, refers to controversies relating to tenurial arrangements over agricultural lands. In this case, the petitioners’ complaint sought the enforcement of an agreement for Monica to cede a portion of the land to Gil and the recovery of their purported hereditary share. The Court found that this did not constitute an agrarian dispute. The Supreme Court emphasized the principle that jurisdiction is determined by the allegations in the complaint and the relief sought, regardless of whether the complainant is entitled to such relief. The High Court quoted the complaint and explained that the essence of the action was the implementation of the private agreement between Monica and Gil and the recovery of a share based on heirship. The complaint did not actually seek to nullify the EP or challenge the implementation of agrarian reform itself.

(d) Agrarian dispute refers to 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 R.A. 6657 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.

The Court also addressed the CA’s ruling that the petitioners were bound by the DARAB’s decision because they participated in the proceedings without objection. Citing Spouses Atuel v. Spouses Valdez, the Supreme Court reiterated that jurisdiction over the subject matter cannot be acquired or waived by the parties’ actions or omissions. Active participation in the proceedings does not vest jurisdiction where none exists by law, and estoppel does not apply to confer jurisdiction on a tribunal that lacks it. As such, the DARAB’s decision was null and void and without effect. Because there was no juridiction, the court reversed the Court of Appeals decision.

FAQs

What was the key issue in this case?	The key issue was whether the DARAB had jurisdiction over a land dispute where no agrarian or tenurial relationship existed between the parties.
What did the Supreme Court decide?	The Supreme Court ruled that the DARAB lacked jurisdiction because the dispute did not involve an agrarian relationship or the implementation of agrarian laws.
What is an Emancipation Patent (EP)?	An Emancipation Patent is a title issued to qualified farmer-beneficiaries under agrarian reform laws, granting them ownership of the land they till.
What is an agrarian dispute?	An agrarian dispute is a controversy relating to tenurial arrangements over agricultural lands, including leasehold, tenancy, or stewardship.
Can parties confer jurisdiction to a court or tribunal by agreement?	No, jurisdiction is conferred by law and cannot be acquired through the agreement or actions of the parties.
What happens when a tribunal makes a decision without jurisdiction?	A decision rendered by a tribunal without jurisdiction is null and void, meaning it has no legal effect.
What was the agreement between Monica and Gil?	Monica allegedly agreed to cede one-third of the land to Gil after she received the Emancipation Patent.
Why was the agreement between Monica and Gil deemed problematic?	The DARAB considered the agreement problematic because it potentially violated agrarian laws prohibiting the transfer of land granted to farmer-beneficiaries.

In conclusion, the Supreme Court’s decision in Heirs of Candido Del Rosario and Heirs of Gil Del Rosario vs. Monica Del Rosario clarifies the boundaries of DARAB jurisdiction, emphasizing that it extends only to genuine agrarian disputes arising from tenurial relationships or the implementation of agrarian reform laws. Disputes falling outside this scope must be resolved in the regular courts, ensuring that property rights are adjudicated in the proper forum.

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: Heirs of Candido Del Rosario vs. Monica Del Rosario, G.R. No. 181548, June 20, 2012