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FELIXBERTO CUBERO v. LAGUNA WEST MULTI-PURPOSE COOPERATIVE

FACTS:

The present petition involves the issue of jurisdiction over the subject matter. The individual petitioners are registered owners of several parcels of land in Batangas. They entered into a Joint Venture Development Agreement with co-petitioner Belle Corporation to develop the properties as an agricultural farm lot subdivision project called "Plantation Hills at Tagaytay Greenlands Phase I." Respondent Laguna West Cooperative filed ex-parte petitions with the Regional Trial Court (RTC) for inscription of an adverse claim on the TCTs of individual petitioners. Respondent claimed that it had entered into Joint Venture Agreements (JVAs) with the individual petitioners' predecessors-in-interest, and it registered the JVAs on the previous owners' titles. In response, the individual petitioners filed a Complaint with the RTC for the annulment of the JVAs. The RTC dismissed the complaint, citing the Department of Agrarian Reform's (DAR) primary jurisdiction to determine the validity or invalidity of agrarian matters. The RTC further noted that the dispute did not involve an agrarian dispute or tenurial relationship. The individual petitioners elevated the case to the Supreme Court, arguing that the case does not constitute an agrarian dispute within the jurisdiction of the DARAB. The Supreme Court denied the petition, stating that the DAR has exclusive original jurisdiction over agrarian reform matters, and the dispute between the parties falls within the DAR's jurisdiction. The Court emphasized that it has consistently held that controversies involving the implementation of the Comprehensive Agrarian Reform Program should be resolved by the DARAB. The Court ruled that the case involves the rights and obligations of persons engaged in the management, cultivation, and use of an agricultural land covered by CARP, and therefore, it falls within the jurisdiction of the DAR.

ISSUES:

  1. Whether the Regional Trial Court (RTC) has jurisdiction over the alleged violation of joint venture agreements involving agricultural lands covered by the Comprehensive Agrarian Reform Program (CARP).

  2. Whether the Department of Agrarian Reform Adjudication Board (DARAB) has exclusive jurisdiction over agrarian disputes.

RULING:

  1. The RTC does not have jurisdiction over the alleged violation of joint venture agreements involving agricultural lands covered by CARP. The Department of Agrarian Reform (DAR) and DARAB have primary and exclusive jurisdiction over agrarian reform matters, including the implementation of joint venture agreements on agricultural lands subject to CARP.

  2. The DARAB has exclusive jurisdiction over agrarian disputes. This includes cases involving the rights and obligations of persons engaged in the management, cultivation, and use of agricultural lands covered by CARP and other agrarian laws. The DARAB's jurisdiction encompasses cases like the present one, which involve the validity of joint venture agreements executed within the prohibitory period under CARP.

PRINCIPLES:

  • The nature of an action, as well as the court's jurisdiction over it, is determined by the allegations in the complaint and the relief sought.

  • The DAR has primary jurisdiction to determine and adjudicate agrarian reform matters, while the DARAB has exclusive jurisdiction over agrarian disputes involving the implementation of CARP.

  • Agrarian disputes may involve various tenurial arrangements beyond the traditional landowner-tenant relationship and are recognized as essential parts of agrarian reform.