In Secretary of the Department of Agrarian Reform vs. Nemesio Dumagpi, the Supreme Court held that land classified as part of a coal mine reservation and later reclassified for agricultural resettlement falls under the jurisdiction of the Department of Agrarian Reform (DAR), not under the rules of acquisitive prescription. This means that individuals cannot claim ownership of such land simply through long-term possession if the land was initially reserved for a specific public purpose. This decision underscores the importance of proper land classification and the primacy of agrarian reform laws in land disputes involving agricultural land previously under government reservation.

From Coal Mine to Conflict: Can Long-Term Possession Trump Agrarian Reform?

This case revolves around a land dispute in Siay, Zamboanga del Sur, where Nemesio Dumagpi claimed ownership of a 22-hectare lot based on his continuous occupation and cultivation since 1945. Dumagpi argued that his long-term possession entitled him to the land, even though he never obtained a formal title. However, the Department of Agrarian Reform (DAR) contested this claim, asserting that the land was part of a former coal mine reservation and later designated for agrarian reform resettlement. This designation, according to DAR, placed the land under its jurisdiction, making Dumagpi’s claim of ownership through acquisitive prescription invalid. The core legal question is whether long-term possession can override the government’s authority to distribute land under agrarian reform laws, particularly when the land was previously reserved for a different public purpose.

The Regional Trial Court (RTC) initially ruled in favor of Nemesio Dumagpi, stating that his continuous occupation had converted the land into his private property. The RTC also ordered the cancellation of the Certificates of Land Ownership Award (CLOAs) issued to Juan Aguilar, Sr., Dionito B. Custodio, and Rosalino C. Valencia, who were awarded portions of the land by the DAR. On appeal, the Court of Appeals (CA) affirmed the RTC’s decision, emphasizing that there was no agrarian relationship between Dumagpi and the private defendants, and thus the case fell outside the jurisdiction of the DAR Adjudication Board (DARAB). However, the Supreme Court reversed these decisions, holding that the land’s history as a coal mine reservation and its subsequent designation for agrarian reform placed it squarely under DAR’s jurisdiction.

The Supreme Court anchored its decision on Article XII, Section 2 of the 1987 Constitution, which states that all lands of the public domain belong to the State. The Court emphasized that only agricultural lands can be alienated, and Dumagpi’s claim failed because the land was not alienable during the period of his claimed possession. Section 48(b) of Commonwealth Act No. 141, or the Public Land Act, allows Filipino citizens to acquire title to alienable public agricultural land through open, continuous, exclusive, and notorious possession for at least 30 years. However, this provision did not apply to Dumagpi because the land was classified as a coal mine reservation from 1938 to 1984.

The court also highlighted the significance of Republic Act No. 6657, or the Comprehensive Agrarian Reform Law (CARL), which placed the reclassified area under the administration and disposition of the DAR. The Court underscored that the CLOAs and Original Certificates of Title (OCTs) issued over the land were part of the implementation of agrarian reform under the DAR Secretary’s exclusive jurisdiction. Nemesio’s challenge to the validity of these CLOAs and OCTs was deemed a collateral attack, which is impermissible, especially since he had no valid title to the land in the first place.

“Even DARAB’s New Rules of Procedure issued on May 30, 1994 expressly recognized, under Section 1(g), Rule II thereof, that matters involving strictly the administrative implementation of R.A. No. 6657, otherwise known as the CARL of 1988 and other agrarian laws as enunciated by pertinent rules, shall be the exclusive prerogative of and cognizable by the Secretary of the DAR.”

The Court also addressed the issue of jurisdiction, stating that the RTC had no authority to decide Civil Case No. 3985 because it involved the implementation of agrarian law, which falls under the exclusive jurisdiction of the DAR Secretary. The court cited Leonor v. CA to emphasize that a void judgment for want of jurisdiction is no judgment at all and cannot be the source of any right or obligation.

This case illustrates the principle that claims of long-term possession cannot override the government’s authority to implement agrarian reform laws. It underscores the importance of proper land classification and the exclusive jurisdiction of the DAR in matters related to agrarian reform. The Supreme Court’s decision serves to protect the rights of agrarian reform beneficiaries and uphold the government’s mandate to distribute land to landless farmers.

FAQs

What was the key issue in this case?	The key issue was whether Nemesio Dumagpi’s long-term possession of land could override the DAR’s authority to distribute it under agrarian reform laws, especially since the land was previously a coal mine reservation.
What did the Supreme Court rule?	The Supreme Court ruled that the land was under the exclusive jurisdiction of the DAR, and Dumagpi’s claim of ownership through long-term possession was invalid.
What is a Certificate of Land Ownership Award (CLOA)?	A CLOA is a document issued by the DAR to qualified agrarian reform beneficiaries, granting them ownership of a portion of agricultural land.
What is acquisitive prescription?	Acquisitive prescription is a legal principle that allows a person to acquire ownership of property through long-term, continuous, and public possession.
Why was Dumagpi’s claim of acquisitive prescription rejected?	His claim was rejected because the land was not alienable during the period of his claimed possession, as it was classified as a coal mine reservation.
What is the role of the DAR in agrarian reform?	The DAR is the lead government agency responsible for implementing agrarian reform, including identifying beneficiaries and distributing agricultural land.
What is the Comprehensive Agrarian Reform Law (CARL)?	The CARL, or Republic Act No. 6657, is the law that governs agrarian reform in the Philippines, aiming to promote social justice and distribute land to landless farmers.
What is a collateral attack on a title?	A collateral attack is an attempt to challenge the validity of a title in a proceeding that is not directly aimed at that purpose, such as in a different lawsuit.
What was the significance of the land being a former coal mine reservation?	The classification as a coal mine reservation meant the land was not alienable during that time, preventing Dumagpi from acquiring ownership through possession.
What is the implication of this ruling for other land disputes?	This ruling reinforces that government-owned lands designated for specific purposes are not subject to private acquisition through long-term possession, especially if those lands are part of agrarian reform initiatives.

In conclusion, the Secretary of the Department of Agrarian Reform vs. Nemesio Dumagpi case provides a clear precedent on the limits of acquisitive prescription when it comes to government-owned land designated for agrarian reform. It reaffirms the DAR’s authority in implementing agrarian reform laws and protecting the rights of qualified beneficiaries. This case serves as a reminder of the importance of understanding land classifications and the legal framework governing land ownership in the Philippines.

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: THE HON. SECRETARY OF THE DEPARTMENT OF AGRARIAN REFORM VS. NEMESIO DUMAGPI, G.R. No. 195412, February 04, 2015