Villaran v. DAR Adjudication Board

G.R. No. 160882 (March 7, 2012)

Facts:

The case revolves around a dispute concerning agrarian reform beneficiaries and the rights to certain parcels of land in Hacienda Jala-Jala, Rizal. The original tenant-tiller, Bernardo Sta. Maria, was issued Certificates of Land Transfer in 1973 under Presidential Decree No. 27, which later led to the issuance of Emancipation Patents and Transfer Certificates of Title in his name. Bernardo passed away on April 5, 1988, but the titles were issued in his name only in December 1988.

Following Bernardo's death, Lorenzo Mariano entered the property, cultivated it, and claimed the harvest. The petitioners, who are Bernardo's heirs, alleged that they only discovered Lorenzo's actions in 1989 and had left the land idle due to insufficient rainfall. Lorenzo contended that he was a long-time sub-tenant of Bernardo and had been cultivating the land even before Bernardo's death.

The conflict escalated to the Barangay Agrarian Reform Committee (BARC) in 1990, which failed to mediate a resolution. Subsequently, Lorenzo filed a petition for the disqualification of the petitioners as agrarian reform beneficiaries and sought the cancellation of the emancipation patents and titles issued to Bernardo. He claimed that he had been a sub-tenant since 1980 and had delivered crop remittances to Bernardo.

The petitioners countered that Lorenzo was merely hired labor and had entered the property unlawfully after Bernardo's death. They argued that the dispute should be resolved in regular courts, asserting that Lorenzo was a mere usurper.

The Regional Adjudicator ruled in favor of Lorenzo, leading to the cancellation of the titles in Bernardo's name and the reallocation of the land to other qualified beneficiaries. The petitioners appealed to the Department of Agrarian Reform Adjudication Board (DARAB), which affirmed the Regional Adjudicator's decision. The petitioners then sought relief from the Court of Appeals through a petition for certiorari under Rule 65, which was dismissed.

Legal Issues:

1. Whether the Court of Appeals erred in dismissing the petition for certiorari filed by the petitioners.
2. Whether the DARAB had jurisdiction over the agrarian dispute between the parties.
3. Whether the petitioners were denied due process in the administrative proceedings.

Arguments:

• Petitioners' Arguments:

  • The petitioners contended that the DARAB lacked jurisdiction over the case, as Lorenzo was merely a squatter or usurper, and the dispute should be resolved in regular courts.
  • They claimed that they were denied due process, alleging partiality in the DARAB's decisions and asserting that the decisions were based on insufficient evidence.
  • They maintained that the proper remedy was a petition for certiorari under Rule 65, as the DARAB's decision was void.

• Respondents' Arguments:

  • The respondents, including the DARAB, argued that the petitioners had resorted to the wrong mode of appeal, as the proper recourse from a DARAB decision is a petition for review under Rule 43.
  • They asserted that the dispute arose from a tenancy relationship, which falls under the jurisdiction of the DARAB.
  • They contended that the petitioners were given ample opportunity to present their case and were not denied due process.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the decision of the Court of Appeals, which had dismissed the petition for certiorari. The Court held that the petitioners had indeed taken the wrong mode of appeal by filing a Rule 65 petition instead of a petition for review under Rule 43. The Court emphasized that the jurisdiction of the DARAB over agrarian disputes is established by law, and the nature of the dispute was agrarian in character, involving tenancy issues.

The Court also noted that the petitioners had failed to demonstrate any reversible error in the findings of the DARAB and the Regional Adjudicator. The factual findings regarding the tenancy relationship between Bernardo and Lorenzo were affirmed, and the Court found no merit in the petitioners' claims of denial of due process. The Court reiterated that procedural due process in administrative proceedings requires only a fair opportunity to be heard, which was provided to the petitioners throughout the proceedings.

Significant Legal Principles Established:

1. The proper mode of appeal from decisions of the DARAB is a petition for review under Rule 43, not a petition for certiorari under Rule 65.
2. The DARAB has primary jurisdiction over agrarian disputes, which include controversies relating to tenancy and land cultivation.
3. Procedural due process in administrative proceedings is satisfied by providing parties with a reasonable opportunity to present their case, whether through oral arguments or written pleadings.