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DEPARTMENT OF AGRARIAN REFORM v. PARAMOUNT HOLDINGS EQUITIES

FACTS:

The petitioner, Department of Agrarian Reform (DAR), filed a Petition for Review challenging the Decision and Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 89693. The CA granted the appeal of respondents Paramount Holdings Equities, Inc., Jimmy Chua, Rojas Chua, Benjamin Sim, Santos C. Tan, William C. Lee, and Stewart C. Lim from the rulings of the Department of Agrarian Reform Adjudication Board (DARAB) in DARAB Case No. 12284.

The DAR filed a petition with the Office of the Provincial Adjudicator seeking to nullify the sale of several parcels of land to the respondents without DAR Clearance as required by the Comprehensive Agrarian Reform Law (CARL). The respondents opposed the petition and argued that the case should be cognizable by the Secretary of Agrarian Reform instead of DARAB. They also sought the dismissal of the petition on the grounds of prescription, litis pendentia, res judicata, and forum shopping.

The Provincial Adjudicator dismissed the petition for lack of jurisdiction, stating that the DARAB's jurisdiction only covers disputes and controversies arising from land already placed under the Comprehensive Agrarian Reform Program (CARP) or other agrarian laws. The DARAB reversed the Provincial Adjudicator's decision on appeal, ruling that the failure to obtain the required clearance indicated fraudulent transactions and that the DAR had the authority to file the petition. The DARAB also asserted its jurisdiction over the case.

The respondents' motion for reconsideration was denied, leading them to file a petition with the CA. The CA eventually rendered a decision in favor of the respondents, setting aside the DARAB's decision.

The DAR filed a Petition for Review with the Supreme Court, which was initially denied due to procedural deficiencies. After subsequent motions and compliance were filed, the Supreme Court granted the DAR's motion for reconsideration and reinstated the petition. The main issue to be resolved is whether the DARAB has jurisdiction over the dispute seeking the nullification of the sale of the subject properties.

ISSUES:

  1. Whether or not the Provincial Agrarian Reform Officer (PARO) has jurisdiction over the subject matter of the case.

  2. Whether or not the petition filed by the PARO sufficiently alleges an agrarian dispute.

  3. Whether the DARAB had jurisdiction over the PARO's petition.

  4. Whether the PARO's petition involves an agrarian dispute.

  5. Whether or not the subject lands are agricultural in nature.

  6. Whether or not the sale of the subject lands falls under the coverage of the Comprehensive Agrarian Reform Program (CARP) and requires clearance from the Department of Agrarian Reform (DAR).

RULING:

  1. No, the PARO does not have jurisdiction over the subject matter of the case.

  2. No, the petition filed by the PARO does not sufficiently allege an agrarian dispute.

  3. The DARAB did not have jurisdiction over the PARO's petition. The DARAB's jurisdiction is limited to disputes involving the annulment or cancellation of lease contracts or deeds of sale involving lands under the administration and disposition of the DAR or LBP, or disputes involving the sale, alienation, mortgage, foreclosure, preemption and redemption of agricultural lands under the coverage of the CARP or other agrarian laws.

  4. The PARO's petition does not involve an agrarian dispute. It called for the declaration of a sale of land null and void, which does not ipso facto make it an agrarian dispute. The DARAB only has jurisdiction over controversies that relate to tenurial arrangements or disputes concerning farmworkers associations.

  5. The Supreme Court dismissed the petition and affirmed the decision of the Court of Appeals. The subject lands were classified as "industrial" prior to the effectivity of the CARL. As such, they are not covered by existing agricultural tenancy laws and do not fall under the ambit of the CARP. Therefore, the sale of the subject lands is not subject to DAR clearance.

PRINCIPLES:

  • The Department of Agrarian Reform (DAR) has primary jurisdiction to determine and adjudicate agrarian reform matters under R.A. No. 6657 and E.O. No. 229.

  • The DAR has exclusive original jurisdiction over all matters involving the implementation of agrarian reform, except those falling under the jurisdiction of the Department of Agriculture (DA) and the Department of Environment and Natural Resources (DENR).

  • Jurisdiction of the Provincial Agrarian Reform Adjudicator (PARAD) and the DAR Adjudication Board (DARAB) is limited to cases involving agrarian disputes and incidents arising from the implementation of agrarian laws.

  • An agrarian dispute refers to any controversy relating to tenurial arrangements over agricultural lands, including disputes concerning farmworkers associations or representation, compensation of lands acquired under agrarian reform laws, and transfer of ownership from landowners to beneficiaries.

  • The DARAB's jurisdiction is limited to disputes involving lease contracts, sale or transfer, mortgage, foreclosure, preemption, and redemption of agricultural lands under the coverage of agrarian laws.

  • For the DARAB to exercise jurisdiction, there must be a tenancy relationship between the parties and the controversy must involve tenurial arrangements or disputes related to agriculture.

  • Agricultural lands are subject to the Comprehensive Agrarian Reform Program (CARP), but industrial lands are not.

  • The classification of lands is determined by the zoning ordinance and the Comprehensive Land Use Plan.