Key Takeaway: The DAR’s Exclusive Jurisdiction in Agrarian Disputes

CRC 1447, Inc. v. Rosalinda Calbatea, et al., G.R. No. 237102, March 04, 2020

Imagine owning a piece of land that you’ve invested in, only to find out that it’s suddenly subject to agrarian reform laws, potentially stripping you of your rights to it. This scenario is not uncommon in the Philippines, where the Comprehensive Agrarian Reform Program (CARP) aims to redistribute land to farmers. The case of CRC 1447, Inc. versus multiple respondents highlights the complexities of land ownership and the crucial role of the Department of Agrarian Reform (DAR) in resolving agrarian disputes. At its core, the case questions whether regular courts or the DAR have jurisdiction over land disputes when the property is covered by CARP.

CRC 1447, Inc. purchased a piece of land that was initially converted from agricultural to industrial use. However, the DAR later issued a Notice of Coverage, reverting it back to agricultural land and sparking a legal battle over who has the right to possess and use the land. The central issue was whether the Regional Trial Court (RTC) or the DAR had jurisdiction over this dispute.

Understanding the Legal Framework of Agrarian Reform

The Philippine legal system has established specific mechanisms to handle disputes related to agrarian reform, primarily through the DAR and its Adjudication Board (DARAB). The Comprehensive Agrarian Reform Law of 1988 (CARL), embodied in Republic Act No. 6657, as amended by Republic Act No. 9700, vests the DAR with primary jurisdiction over agrarian reform matters. Section 50 of RA 6657 states that the DAR has “exclusive original jurisdiction over all matters involving the implementation of agrarian reform.”

Key terms like “agrarian dispute” and “Notice of Coverage” are central to understanding this case. An agrarian dispute involves the rights and obligations of persons engaged in the management, cultivation, or use of agricultural lands covered by the CARL. A Notice of Coverage is a document issued by the DAR, informing the landowner that their property has been identified as part of the CARP, marking the beginning of the land acquisition process.

To illustrate, consider a farmer who has been tilling a piece of land for years, believing it to be his own, only to discover that the land is now subject to CARP due to a Notice of Coverage. This scenario would fall under the DAR’s jurisdiction, as it involves an agrarian dispute.

The Journey of CRC 1447, Inc. Through the Courts

The case began when CRC 1447, Inc. purchased a property in 2006, which was initially converted from agricultural to industrial use in 1999. However, in 2007, the DAR issued a Notice of Coverage, reverting the land back to agricultural status. CRC 1447, Inc. attempted to lift this Notice, but their efforts were denied by the DAR in 2013.

In 2014, CRC 1447, Inc. filed a complaint for recovery of possession against the respondents, who were actual occupants and potential agrarian reform beneficiaries. The respondents argued that the case was an agrarian dispute and should be handled by the DARAB, not the RTC. The RTC dismissed the case for lack of jurisdiction, a decision that was later affirmed by the Court of Appeals (CA).

The Supreme Court, in its decision, emphasized the DAR’s exclusive jurisdiction over agrarian disputes. Justice Reyes, Jr. stated, “The jurisdiction of the DAR is laid down in Section 50 of R.A. No. 6657, as amended by R.A. No. 9700, which vests the DAR with primary jurisdiction to determine and adjudicate agrarian reform matters.” The Court further clarified that “all cases involving agrarian matters, which include issues on the management, cultivation, or use of all agricultural lands covered by the CARL, are within the jurisdiction of the DARAB.”

The procedural steps in this case highlight the importance of recognizing the DAR’s jurisdiction early in any agrarian-related dispute:

• CRC 1447, Inc. filed a petition to lift the Notice of Coverage, which was denied by the DAR.
• The company then sought recovery of possession through the RTC, which dismissed the case due to the DAR’s jurisdiction.
• The CA affirmed the RTC’s decision, leading to the Supreme Court’s final ruling on the matter.

Practical Implications and Key Lessons

This ruling reinforces the DAR’s role as the primary authority in agrarian disputes, affecting how similar cases are handled in the future. Property owners and businesses must be aware that any land covered by CARP falls under the DAR’s jurisdiction, regardless of prior conversions or ownership changes.

For individuals and companies dealing with land disputes, it’s crucial to:

• Verify the status of the land with the DAR before any purchase or development.
• Understand that a Notice of Coverage can revert land to agricultural use, affecting property rights.
• Seek legal advice from experts in agrarian law to navigate the complexities of CARP.

Key Lessons:

• Always check the agrarian status of land before any transaction.
• Be prepared for the DAR’s involvement if the land is covered by CARP.
• Engage with agrarian reform beneficiaries and the DAR early in any dispute to avoid jurisdictional issues.

Frequently Asked Questions

What is the Comprehensive Agrarian Reform Program (CARP)?

CARP is a Philippine government program aimed at redistributing land to farmers to promote social justice and economic development.

What is a Notice of Coverage?

A Notice of Coverage is a document issued by the DAR, indicating that a piece of land has been identified for inclusion in the CARP.

Can the DAR’s jurisdiction be challenged in court?

While the DAR’s jurisdiction can be questioned, the Supreme Court has consistently upheld its exclusive authority over agrarian disputes.

What should I do if my land is subject to a Notice of Coverage?

Consult with a lawyer specializing in agrarian law to understand your rights and options, and engage with the DAR to address the issue.

How can I protect my property from being included in CARP?

Ensure that your land is properly documented and classified as non-agricultural, and seek legal advice to maintain its status.

What are the rights of agrarian reform beneficiaries?

Agrarian reform beneficiaries have the right to own and cultivate the land awarded to them under CARP, subject to certain conditions and obligations.

Can a property be converted from agricultural to non-agricultural use?

Yes, but such conversions require approval from the DAR and other relevant government agencies.

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