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CENTRAL MINDANAO UNIVERSITY v. DARAB

FACTS:

The case involves a petition filed by the Bukidnon Free Farmers and Agricultural Laborers Organization (BUFFALO) against the Central Mindanao University (CMU). The complaint seeks to have the CMU declared as tenants under the Comprehensive Agrarian Reform Program (CARP). CMU is an agricultural educational institution owned by the state. It began as a farm school in 1910 and later expanded into an agricultural university. The CMU implemented a program called "Kilusang Sariling Sikap Program" wherein faculty and employees were allowed to lease land resources for cultivation. This program aimed to provide training and additional income to the participants. However, when a new CMU President discontinued the program, the complainants were laid off.

In 1986, CMU launched the CMU-Income Enhancement Program (CMU-IEP) which allowed CMU employees to use 4 to 5 hectares of land for one year, paying a service fee and land rental fee. This program was later extended to former employees. An Addendum to the Memorandum of Agreement (MOA) was signed, allowing former employees to participate in the CMU-IEP and cultivate one hectare of land for a lowland rice project.

Several complainants, including Obrique, filed a complaint claiming to be tenants or landless peasants occupying a portion of CMU's property. However, the DARAB found that based on the agreements they signed, there was no landlord-tenant relationship and CMU did not share in the produce of the participants' labor. Obrique, who was separated from service for mishandling funds, was found to be a Physics Instructor at CMU and not a landless peasant.

The CMU sought a review of the DARAB and Court of Appeals' decisions, questioning the jurisdiction of DARAB and the alleged errors committed by the Court of Appeals. The CMU argued that the respondents were considered squatters as their continued stay was unauthorized and without legal authority. They also argued that persons guilty of prohibited acts like forcible entry or illegal detainer, such as the respondents, do not qualify as beneficiaries of agrarian reform.

ISSUES:

  1. Whether the private respondents can qualify as beneficiaries under the Comprehensive Agrarian Reform Program (CARP).

  2. Whether the land occupied by the private respondents is exempted or excluded from the coverage of CARP.

  3. Whether the portion of the CMU land ordered segregated is covered by the CARP.

  4. Whether the DARAB has jurisdiction over the case involving the CMU's titled school site.

  5. Whether the DARAB has the authority to order the segregation of a portion of a private property titled in the name of its lawful owner, even if the claimant is not entitled as a beneficiary.

RULING:

  1. The private respondents, not being tenants nor proven to be landless peasants, cannot qualify as beneficiaries under CARP.

  2. The land occupied by the private respondents is exempted from the coverage of CARP as it is a school site and campus including an experimental farm station operated by a public school for educational purposes.

  3. The portion of the CMU land ordered segregated is not covered by the CARP because it is not alienable and disposable land of the public domain. It is private land registered and titled in the name of the CMU. Furthermore, it is exempt from coverage under Section 10 of R.A. 6657 because it is actually, directly, and exclusively used and found to be necessary for school site and campus, including experimental farm stations for educational purposes.

  4. The DARAB does not have jurisdiction over the case involving the CMU's titled school site because its jurisdiction is limited to matters involving the implementation of the CARP, specifically agrarian cases and controversies involving lands falling within the coverage of the program. The CMU's land, being necessary for school sites, campuses, and other educational purposes, does not fall within the jurisdiction of the DARAB.

  5. The DARAB does not have the authority to order the segregation of a portion of a private property titled in the name of its lawful owner, if the claimant is not entitled as a beneficiary. The quasi-judicial powers of the DARAB, as provided in Executive Order No. 129-A and Section 50 of R.A. 6657, grant jurisdiction over agrarian reform matters and determine agrarian disputes related to tenurial rights over lands devoted to agriculture. In this case, the complainants are not entitlement to claim as beneficiaries of CARP, as they are not share tenants or leaseholders. Therefore, the DARAB's order for the segregation of a portion of the CMU land was without legal authority.

PRINCIPLES:

  • Squatters cannot claim rights to a property under the CARP if their entry into the land is unauthorized and without legal authority.

  • Persons guilty of committing prohibited acts of forcible entry or illegal detainer do not qualify as beneficiaries under CARP.

  • Lands actually, directly, and exclusively used for school sites and campuses, including experimental farm stations operated by public or private schools for educational purposes, are exempted from the coverage of CARP.

  • Lands that are not alienable and disposable land of the public domain and are privately owned and registered are not covered by the CARP.

  • Lands that are actually, directly, and exclusively used and found to be necessary for school sites, campuses, and other educational purposes are exempt from coverage under Section 10 of R.A. 6657.

  • The jurisdiction of the DARAB is limited to matters involving the implementation of the CARP, specifically agrarian cases and controversies involving lands falling within the coverage of the program. It does not include lands necessary for school sites, campuses, and other educational purposes.

  • Quasi-judicial powers of the DARAB are provided in Executive Order No. 129-A and Section 50 of R.A. 6657.

  • The DARAB has jurisdiction to try and decide agrarian disputes in the implementation of the CARP.

  • An agrarian dispute is defined as any controversy relating to tenurial rights over lands devoted to agriculture.

  • The quasi-judicial function of the DARAB does not carry greater authority than ordinary courts to make an award beyond the relief sought by the complainants/petitioners.

  • Taking private property to be awarded to uncertain beneficiaries is a misinterpretation of the authority and jurisdiction granted by law to the DARAB.

  • State colleges and universities are exempt from CARP to preserve their resources and research facilities for scientific and technological advancement in agriculture.