TL;DR

The Supreme Court ruled that the Department of Agrarian Reform Adjudication Board (DARAB) lacks jurisdiction over cases involving the cancellation of Certificates of Land Ownership Award (CLOAs) unless there is an existing agrarian dispute, specifically a tenurial arrangement, between the landowner and the agrarian reform beneficiaries. In this case, the dispute centered on land ownership and the administrative implementation of agrarian reform, which falls under the jurisdiction of the DAR Secretary, not the DARAB. This decision clarifies the boundaries of DARAB’s jurisdiction, emphasizing that it is limited to resolving disputes directly related to tenurial arrangements and agrarian reform implementation between landowners and tenants, protecting landowners from unwarranted CLOA cancellations.

Land Title Clash: When is a Land Dispute an Agrarian Dispute?

This case revolves around a dispute over a parcel of land in Masbate. Delia Sutton, claiming ownership through inheritance and a prior sale, sought to cancel the CLOA issued to Romanito P. Lim and his sons. The core legal question is whether the DARAB has jurisdiction to resolve the dispute, or whether the matter falls under the administrative authority of the DAR Secretary.

The central issue before the Supreme Court was whether the DARAB had jurisdiction to entertain a petition for cancellation of a Certificate of Land Ownership Award (CLOA) and the corresponding title. The Court examined Section 1, Rule II of the 1994 DARAB Rules of Procedure, which outlines the board’s primary and exclusive jurisdiction over agrarian disputes involving the implementation of the Comprehensive Agrarian Reform Program (CARP). The Court emphasized that while the DARAB may entertain petitions for cancellation of CLOAs, its jurisdiction is confined only to agrarian disputes, which must relate to a tenurial arrangement between landowners and tenants. Building on this principle, the Court reiterated that cases involving CLOA cancellations arising from the administrative implementation of agrarian reform laws, rules, and regulations, where the parties are not agricultural tenants or lessees, fall within the jurisdiction of the DAR Secretary, not the DARAB.

An agrarian dispute, as defined in Section 3(d) of R.A. No. 6657, relates to any controversy concerning tenurial arrangements over lands devoted to agriculture. These arrangements include leasehold, tenancy, or stewardship. The Court clarified that an agrarian dispute must be a controversy relating to a tenurial arrangement over lands devoted to agriculture. Tenurial arrangements pertain to agreements that set out the rights between a landowner and a tenant, lessee, farm worker, or other agrarian reform beneficiary involving agricultural land. Traditionally, tenurial arrangements are in the form of tenancy or leasehold arrangements. However, other forms such as a joint production agreement to effect the implementation of CARP have been recognized as a valid tenurial arrangement.

The Court clarified that the tenurial, leasehold, or agrarian relations may be established with the concurrence of several elements: (1) the parties are the landowner and the tenant or agricultural lessee; (2) the subject matter of the relationship is an agricultural land; (3) there is consent between the parties to the relationship; (4) the purpose of the agricultural relationship is to bring about agricultural production; (5) there is personal cultivation on the part of the tenant or agricultural lessee; and (6) the harvest is shared between the landowner and the tenant or agricultural lessee. This approach contrasts with the petitioner’s argument that an agrarian dispute can be dissected into purely tenurial and non-tenurial arrangements. In this case, Delia Sutton’s claims were based solely on the alleged erroneous grant of the CLOA to the Lims, asserting her ownership and the land’s exemption from CARP coverage. Sutton failed to allege any tenurial arrangement between the parties, negating the existence of an agrarian dispute and the DARAB’s jurisdiction.

In light of these considerations, the Supreme Court affirmed the Court of Appeals’ decision, emphasizing that the controversy between Sutton and the Lims was not agrarian in nature. It merely involved the administrative implementation of the agrarian reform program, which is cognizable by the DAR Secretary. Furthermore, the Court noted that under R.A. No. 9700, which took effect on July 1, 2009, all cases involving the cancellation of CLOAs and other titles issued under any agrarian reform program are now within the exclusive and original jurisdiction of the DAR Secretary. Consequently, the DARAB lacked jurisdiction to entertain the controversy, rendering its decision null and void. The jurisdiction lies with the Office of the DAR Secretary to resolve the issues of land classification and identification of qualified beneficiaries.

FAQs

In conclusion, the Sutton v. Lim case underscores the significance of establishing an agrarian dispute, particularly a tenurial arrangement, to invoke the jurisdiction of the DARAB in CLOA cancellation cases. The ruling reinforces the DAR Secretary’s authority over administrative matters related to agrarian reform implementation, ensuring that disputes are resolved within the appropriate legal framework.

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.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: Delia T. Sutton v. Romanito P. Lim, G.R. No. 191660, December 03, 2012