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RUFINA VDA. DE TANGUB v. CA

FACTS:

Rufina Tangub and her late husband filed a case for damages against the Spouses Martil, alleging unlawful dispossession as tenants from a landholding. They also impleaded the PNB, claiming that it foreclosed on the property and sold portions of the land. The Tangub Spouses sought to annul the mortgage and related transactions. The RTC dismissed the complaint, relying on Executive Order No. 229 and Executive Order No. 129-A transferring agrarian cases to the DAR. The Court of Appeals affirmed the RTC's ruling. Rufina Tangub filed a petition with the Supreme Court, arguing that the dismissal was illegal and unconstitutional. The Supreme Court upheld the dismissal, referring to the provisions of the executive orders which granted the DAR quasi-judicial powers over agrarian reform matters and jurisdiction over the implementation of agrarian reform. It held that the DAR had the authority to resolve agrarian conflicts, land tenure problems, and approve or disapprove the conversion of agricultural lands.

ISSUES:

  1. Whether the Regional Trial Court, acting as a special agrarian court, has jurisdiction over agrarian cases in light of Executive Orders Numbered 129-A and 229 and Republic Act No. 6657.

RULING:

  1. The Court held that the Regional Trial Court does not have jurisdiction over agrarian cases. The jurisdiction was transferred to the Department of Agrarian Reform by virtue of Executive Orders Numbered 129-A and 229, in relation to Republic Act No. 6657. The Department of Agrarian Reform has the power to determine and adjudicate agrarian reform matters, resolve agrarian conflicts and land tenure related problems, and approve or disapprove the conversion of agricultural lands.

PRINCIPLES:

  • The Department of Agrarian Reform has quasi-judicial powers to determine and adjudicate agrarian reform matters.

  • The jurisdiction of the Regional Trial Court over agrarian cases has been transferred to the Department of Agrarian Reform.

  • The Department of Agrarian Reform has the authority to approve or disapprove the conversion of agricultural lands.