TL;DR

The Supreme Court definitively ruled that Regional Trial Courts (RTCs) do not have jurisdiction to hear cases seeking the cancellation of Certificates of Land Ownership Award (CLOAs). This authority is exclusively vested in the Secretary of the Department of Agrarian Reform (DAR). The Court emphasized that when a case primarily aims to cancel a CLOA issued under the Comprehensive Agrarian Reform Program (CARP), it falls under the administrative jurisdiction of the DAR Secretary, not the judicial purview of the RTC. Consequently, any proceedings conducted by the RTC in such cases, including judgments, are considered null and void from the outset. This decision underscores the importance of correctly identifying the proper forum for agrarian disputes, ensuring that cases involving CLOA cancellation are directed to the DAR Secretary for resolution, thereby upholding the specialized jurisdiction designed for agrarian reform matters.

Whose Court? Navigating the Legal Terrain of CLOA Cancellation: RTCs or the DAR Secretary?

The case of Spouses Ybiosa v. Drilon revolves around a land dispute that highlights a crucial aspect of Philippine agrarian law: jurisdiction over the cancellation of Certificates of Land Ownership Award (CLOAs). Inocencio Drilon initiated a legal battle in the Regional Trial Court (RTC) seeking to annul a Deed of Absolute Sale held by Spouses Fredeswinda and Alfredo Ybiosa, and consequently, to invalidate their Original Certificate of Title which stemmed from a CLOA. Inocencio claimed ownership based on receipts of purchase from the late Gabriel Drilon, while the Ybosas held a Deed of Sale and the CLOA-derived title. The RTC initially declared the Deed of Sale to the Ybosas void due to fraud but also dismissed Inocencio’s claim and acknowledged its lack of jurisdiction over CLOA cancellation. The Court of Appeals (CA), on appeal, partially granted Inocencio’s appeal, validating the sale in his favor and voiding the Ybosas’ Deed of Sale, yet still recognized the DAR’s authority over CLOA cancellation.

However, the Supreme Court took a different stance, zeroing in on the fundamental issue of jurisdiction. The Court underscored that the primary relief sought by Inocencio was effectively the cancellation of the Ybosas’ CLOA and the derivative Original Certificate of Title. Referencing the 1994 DARAB Rules of Procedure, which were in effect when the case was initially filed, and subsequent legal frameworks including Republic Act No. 9700 (CARPER Law) and DAR Administrative Order No. 3, series of 2009, the Supreme Court clarified the jurisdictional landscape. These legal instruments unequivocally place the authority to hear and decide cases involving the issuance, correction, and cancellation of CLOAs under the primary and exclusive jurisdiction of the Department of Agrarian Reform (DAR), specifically the DAR Secretary in cases not involving agrarian disputes between landowners and tenants.

The Court elucidated that while the Department of Agrarian Reform Adjudication Board (DARAB) has jurisdiction over agrarian disputes, which are controversies related to tenurial arrangements, cases concerning CLOA cancellation that do not stem from such agrarian disputes, but rather from administrative implementation of agrarian reform laws, fall under the jurisdiction of the DAR Secretary. The Supreme Court cited the precedent case of Heirs of Santiago Nisperos v. Nisperos-Ducusin, which reinforces this distinction, stating that cases involving CLOA cancellation for parties who are not agricultural tenants or lessees are within the DAR Secretary’s jurisdiction, not the DARAB or the RTC. The key factor is whether an agrarian dispute exists, defined by Republic Act No. 6657 as controversies relating to tenurial arrangements over agricultural lands. In the Ybiosa v. Drilon case, the Court found no indication of a tenancy relationship between the parties, thus placing the CLOA cancellation issue squarely within the DAR Secretary’s administrative jurisdiction.

Consequently, the Supreme Court concluded that the RTC, and by extension the CA, acted without jurisdiction when they entertained Civil Case No. 11985. As the RTC lacked subject matter jurisdiction from the outset, all proceedings, including the trial, reception of evidence, and the RTC’s decision, were deemed null and void. The CA’s subsequent decision, premised on the RTC proceedings, was similarly invalidated. The Supreme Court emphasized that the pronouncements made by the CA regarding ownership were also erroneous because they were based on proceedings conducted by a court without proper jurisdiction. The proper course of action for Inocencio Drilon, if he wished to pursue the cancellation of the CLOA and title, was to file a case with the DAR Secretary.

This ruling serves as a critical reminder regarding the delineation of jurisdiction in agrarian reform cases. It underscores the specialized nature of agrarian disputes and the administrative processes established for implementing CARP. Litigants must carefully assess the nature of their claims and ensure they are filed in the correct forum. Seeking CLOA cancellation requires recourse to the DAR Secretary, unless it is intrinsically linked to an agrarian dispute falling under DARAB’s jurisdiction. Filing such cases in the RTC not only results in wasted time and resources but also renders all proceedings legally ineffective.

FAQs

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: YBIOSA v. DRILON, G.R. No. 212866, April 23, 2018