The Supreme Court has definitively ruled that the Department of Agrarian Reform Adjudication Board (DARAB) holds primary and exclusive jurisdiction over cases involving the cancellation of Certificates of Land Ownership Award (CLOAs). This means that any legal challenge to a CLOA, including its annulment, must be initially filed with the DARAB, not with regular courts. The ruling reinforces the DARAB’s mandate to resolve disputes arising from the implementation of the Comprehensive Agrarian Reform Program (CARP) and ensures that agrarian reform matters are handled by a specialized body.

Land Disputes: Can Regular Courts Override DARAB’s Jurisdiction?

Philippine Veterans Bank (PVB) sought to annul CLOAs issued to Lazaro and Francisco Cruz, arguing that the land was outside CARP coverage. PVB filed its case in the Regional Trial Court (RTC) of Bulacan, but the Court of Appeals ultimately sided with the DARAB’s exclusive jurisdiction. This legal battle highlights a recurring question: when does a regular court have the power to intervene in agrarian reform matters? The Supreme Court addressed this question by affirming the DARAB’s authority, providing clarity on the scope of its mandate, and ensuring that agrarian reform disputes are handled by a specialized body.

The heart of the issue lies in determining which body has the power to decide the fate of CLOAs. PVB initiated the legal proceedings by filing a Complaint for the annulment of the CLOAs, alleging that these were illegally and fraudulently issued. The bank maintained that although unirrigated, the property remained agricultural. The RTC initially took cognizance of the case, but both the public and private respondents challenged the court’s jurisdiction, asserting that the DARAB should be the proper forum given Section 50 of Republic Act No. 6657 (CARP Law). The Court of Appeals, after initially siding with the RTC, reversed its decision upon learning that the CLOAs had been entered in the Registry of Deeds, solidifying DARAB’s jurisdiction.

The Supreme Court, in its analysis, anchored its decision on established legal precedents and statutory provisions. The Court emphasized the principle that jurisdiction is determined by the allegations in the Complaint. PVB’s own Complaint sought the annulment of CLOAs on what they claimed was agricultural land. This, in itself, placed the dispute squarely within the ambit of agrarian reform, irrespective of any later claims about the land’s status. This position is supported by SSS v. DAR, which affirmed the DARAB’s jurisdiction over cases involving CLOAs.

Section 1, Rule II, 2002 DARAB Rules of Procedure provides that:

Section 1. Primary And Exclusive Original and Appellate Jurisdiction. – The board shall have primary and exclusive jurisdiction, both original and appellate, to determine and adjudicate all agrarian disputes involving the implementation of the Comprehensive Agrarian Reform Program (CARP) under Republic Act No. 6657, Executive Order Nos. 228, 229, 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.

Building on this principle, the Supreme Court underscored the significance of Section 50 of R.A. 6657, which confers upon the DAR the power to adjudicate agrarian reform matters. Executive Order No. 129-A further clarifies this authority by creating the DARAB, specifically tasked with handling agrarian reform cases. The Court reiterated its stance from previous cases, such as Rivera v. Del Rosario and David v. Rivera, emphasizing that jurisdiction over agrarian reform matters is now expressly vested in the DAR through the DARAB.

The Court tackled PVB’s concern that the DARAB adjudicator was a party to the case, but dismissed the argument that this might influence the DARAB’s jurisdiction. It held that jurisdiction is determined by the law and the allegations in the complaint, not the identities of the parties involved. Further, the Court noted that it was unlikely that the impleaded adjudicator would be assigned to hear the same case if filed before the DARAB. Finally, the Court declined to rule on the constitutionality of Rule II, Section 1(1.6) of the DARAB Rules of Procedure, as this issue was raised too late in the proceedings. This is because the petitioner, PVB, only questioned its constitutionality in their memorandum.

FAQs

What is a CLOA?	A Certificate of Land Ownership Award (CLOA) is a title document issued to agrarian reform beneficiaries, granting them ownership of the land they till.
What is DARAB?	The Department of Agrarian Reform Adjudication Board (DARAB) is a quasi-judicial body under the Department of Agrarian Reform (DAR) responsible for resolving agrarian disputes.
What law gives DARAB its authority?	Republic Act No. 6657, also known as the Comprehensive Agrarian Reform Law (CARP), as well as Executive Order No. 129-A, outlines the DARAB’s jurisdiction and powers.
Can the RTC hear cases involving CLOAs?	Generally, no. The DARAB has primary and exclusive jurisdiction over cases involving the cancellation, correction, or annulment of CLOAs.
What happens if a CLOA is illegally issued?	An action for cancellation of the CLOA can be filed with the DARAB. If proven, the DARAB can order the cancellation and the reallocation of the land to qualified beneficiaries.
What happens if a DARAB adjudicator is a party to the case?	The adjudicator will most likely be inhibited from hearing the case to guarantee an impartial and independent tribunal.
What is an agrarian dispute?	An agrarian dispute is any controversy relating to tenurial arrangements or the implementation of agrarian reform laws, including disputes over land ownership, leasehold agreements, and compensation.
Does this ruling affect all types of land?	This ruling specifically applies to agricultural lands covered by the Comprehensive Agrarian Reform Program (CARP).
What does primary jurisdiction mean?	Primary jurisdiction means that the DARAB is the first venue where such cases must be filed and resolved, before any appeal can be brought before another court.

In conclusion, the Supreme Court’s decision reinforces the DARAB’s vital role in resolving agrarian disputes. This serves to promote agrarian reform by ensuring that disputes involving CLOAs are handled by a specialized body with expertise in agrarian law and policy.

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: PHILIPPINE VETERANS BANK VS. COURT OF APPEALS, G.R. NO. 132561, June 30, 2005