Navigating Jurisdiction in Agrarian Disputes: A Guide to DARAB’s Authority

DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD (DARAB) AND PROVINCIAL AGRARIAN REFORM ADJUDICATOR FE ARCHE-MANALANG, DEPARTMENT OF AGRARIAN REFORM (DAR), PETITIONERS,VS.COURT OF APPEALS, BSB CONSTRUCTION AND AGRICULTURAL DEVELOPMENT CORPORATION, AND CAROL BAUCAN, RESPONDENTS. G.R. Nos. 113220-21, January 21, 1997

Imagine a farmer facing eviction from land they’ve cultivated for years. Or a developer halted mid-project due to agrarian claims. Understanding the Department of Agrarian Reform Adjudication Board’s (DARAB) jurisdiction is crucial in these situations. This case clarifies the boundaries of DARAB’s authority in agrarian disputes, particularly the relationship between the central board and its regional adjudicators.

This article explores the landmark case of DARAB vs. Court of Appeals, providing a comprehensive breakdown of the legal principles, practical implications, and frequently asked questions surrounding DARAB’s jurisdiction. It serves as a guide for landowners, farmers, and legal professionals alike to navigate the complexities of agrarian reform adjudication in the Philippines.

Understanding DARAB’s Mandate: Legal Framework

The Comprehensive Agrarian Reform Program (CARP), instituted through Republic Act No. 6657, aims to promote social justice by redistributing land to landless farmers. The DARAB is the quasi-judicial body tasked with resolving agrarian disputes arising from the implementation of CARP.

Section 50 of R.A. No. 6657 explicitly states: “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).” This provision grants DARAB broad authority over agrarian issues.

However, to streamline the adjudication process, the DARAB has established a hierarchical structure, delegating some of its authority to Regional Agrarian Reform Adjudicators (RARADs) and Provincial Agrarian Reform Adjudicators (PARADs). The DARAB Revised Rules of Procedure outlines this delegation, specifying the roles and responsibilities of each level.

It’s crucial to distinguish between primary jurisdiction, which initially resides with the DARAB, and delegated jurisdiction, exercised by the RARADs and PARADs. The DARAB retains appellate jurisdiction over decisions made by the RARADs and PARADs, ensuring a system of checks and balances within the agrarian justice system.

Case Summary: DARAB vs. Court of Appeals

This case arose from a land dispute in Antipolo, Rizal, where BSB Construction sought to develop a parcel of land into a housing subdivision. Several groups of farmers claimed tenancy rights over the land, arguing that they were entitled to the benefits of CARP.

• Two separate cases were filed: one with the PARAD (the ABOGNE Case) and another with the DARAB itself (the BEA Case).
• The PARAD issued a Temporary Restraining Order (TRO) against BSB Construction, halting development activities.
• Simultaneously, the DARAB issued a Status Quo Order (SQO) with similar effect.
• BSB Construction challenged both orders in the Court of Appeals, arguing that the land was not agricultural and the claimants were mere squatters.

The Court of Appeals ruled in favor of BSB Construction, nullifying the DARAB’s SQO and questioning the DARAB’s jurisdiction over the BEA Case. The DARAB then appealed to the Supreme Court.

The Supreme Court ultimately sided with the Court of Appeals, affirming the principle that the DARAB’s original jurisdiction is exercised primarily through the PARADs and RARADs. The Court emphasized the importance of adhering to the DARAB Revised Rules of Procedure.

The Supreme Court stated: “It indisputably follows that all actions pursued under the exclusive original jurisdiction of the DAR, in accordance with §50 of R.A. No. 6657, must be commenced in the PARAD of the province where the property is located and that the DARAB only has appellate jurisdiction to review the PARAD’s orders, decisions and other dispositions.”

The Court further clarified that while the DARAB has primary jurisdiction, this jurisdiction is delegated to the PARADs and RARADs for efficient case management. The DARAB cannot bypass these lower bodies and directly assume jurisdiction over cases that fall within their territorial competence.

The Supreme Court also held that the DARAB should have referred the BEA Case to the PARAD of Rizal for consolidation with the ABOGNE Case. This would have avoided multiplicity of suits and ensured a more streamlined adjudication process.

Practical Implications of the Ruling

This case underscores the importance of understanding the jurisdictional boundaries within the DARAB system. It clarifies that while the DARAB has broad authority over agrarian disputes, it must adhere to its own rules and respect the delegated authority of the RARADs and PARADs.

For landowners and developers, this means ensuring that agrarian claims are properly addressed at the PARAD level before escalating to the DARAB. For farmers, it reinforces the importance of filing their claims with the correct PARAD to ensure their rights are protected.

Key Lessons:

• Agrarian disputes must generally be initiated at the PARAD level.
• The DARAB’s role is primarily appellate, reviewing decisions of the RARADs and PARADs.
• The DARAB Revised Rules of Procedure must be strictly followed to ensure due process and orderly adjudication.

Frequently Asked Questions (FAQs)

Q: What is the DARAB’s primary role?

A: The DARAB is the quasi-judicial body responsible for resolving agrarian disputes arising from the implementation of CARP.

Q: Where should I file an agrarian dispute?

A: Generally, you should file your case with the Provincial Agrarian Reform Adjudicator (PARAD) of the province where the land is located.

Q: Can the DARAB directly take over a case already filed with the PARAD?

A: No, the DARAB generally cannot directly take over a case already filed with the PARAD, as this would violate the principle of delegated jurisdiction.

Q: What is the difference between original and appellate jurisdiction?

A: Original jurisdiction refers to the authority to hear a case for the first time. Appellate jurisdiction refers to the authority to review decisions made by lower courts or tribunals.

Q: What should I do if I believe the PARAD made an incorrect decision?

A: You can appeal the PARAD’s decision to the DARAB within the prescribed period.

Q: What happens if the DARAB violates its own rules of procedure?

A: Actions taken by the DARAB in violation of its own rules may be deemed invalid and subject to legal challenge.

Q: How does land classification affect DARAB jurisdiction?

A: DARAB jurisdiction generally extends to agricultural lands covered by CARP. If land has been validly reclassified as non-agricultural prior to the effectivity of CARP, it may fall outside DARAB’s jurisdiction.

ASG Law specializes in agrarian reform law and litigation. Contact us or email hello@asglawpartners.com to schedule a consultation.