The Supreme Court has GRANTED the petition of Janette Pena and Bob Guinto and DISMISSED a Petition for Reallocation filed by a group of farmers over a titled parcel of land in Tarlac City, ruling that the Department of Agrarian Reform (DAR) had no jurisdiction to order the cancellation of a Torrens title through such a petition.
The Court reversed the Resolutions of the Court of Appeals (CA) and held that a certificate of title may only be challenged through a direct proceeding, not through a petition for reallocation.
The Case
The Cruz and Sioson Estate, formerly known as the Valdez Estate, spans approximately 150 hectares in Barangay Balingcanaway, Tarlac City. Since 1990, landless farmers, referred to collectively as Quiani et al., allegedly occupied and cultivated parcels of land there and had been regularly paying lease rentals to the estate's administrators.
They averred that the subject property was subjected to Comprehensive Agrarian Reform Program coverage under Republic Act No. 6657 and had already been distributed to farmer-beneficiaries. They claimed that the awardees illegally sold their awarded portions to Pena, Guinto, and others, resulting in the transfer of lands under the names of the landowners' relatives or nominees. Transfer Certificate of Title (TCT) No. 370629 was issued to Andresito Boiser, Jr., while TCT No. 363864, containing more or less seven hectares, was issued to Pena and Guinto.
Quiani et al. filed a Petition for Reallocation with the DAR. Pena and Guinto filed their Opposition, denying the allegations and asserting that the land covered by TCT No. 363864 is not for sale. They argued the land fell outside the scope of Republic Act No. 6657, as amended by Republic Act No. 9700, and that no tenancy relationship existed between the parties.
The DAR Regional Director dismissed the Petition for Reallocation for lack of sufficient basis. On appeal, the DAR Secretary initially affirmed the dismissal but later, on motion for reconsideration, granted the motion and ordered proceedings for the cancellation of the titles and the initiation of reallocation proceedings. Pena and Guinto then filed a Petition for Review before the CA, which was dismissed for failing to observe the principle of exhaustion of administrative remedies and due to procedural infirmities.
The Issue
The central question was whether the DAR Regional Director and the DAR Secretary had jurisdiction to entertain the Petition for Reallocation and order the cancellation of the petitioners' Torrens title.
The Ruling
The Supreme Court ruled that the DAR Regional Director and the DAR Secretary erred in entertaining the Petition for Reallocation. By ordering the initiation of proceedings for the cancellation of the title, the DAR Secretary effectively authorized a collateral attack, an act beyond its jurisdiction.
The Court declared that under Presidential Decree No. 1529, certificates of title may only be assailed through a direct proceeding. It held that titles derived from emancipation patents or certificates of land ownership award are conferred with the same indefeasibility and security afforded to all Torrens titles, and their validity may only be challenged through a direct proceeding.
The dispositive portion reads: "ACCORDINGLY, the Petition is GRANTED. The December 27, 2022 and the September 19, 2024 Resolutions of the Court of Appeals in CA-G.R. SP No. 176299 are REVERSED. The Petition for Reallocation instituted by Domingo Quiani, Sr. et al. is DISMISSED without prejudice to the filing of the appropriate petition to challenge the validity of the issuance of Transfer Certificate of Title No. 363864."
By the Numbers
- G.R. No. 276299
- Estate area: approximately 150 hectares in Barangay Balingcanaway, Tarlac City
- TCT No. 363864 contains more or less seven hectares
- CA Resolutions dated December 27, 2022 and September 19, 2024
- DAR Secretary Order reversed was dated March 6, 2018
- DAR Secretary Order granting reconsideration dated February 12, 2020
- DAR Regional Director Order dated January 14, 2011
- Farmers allegedly occupied the land since 1990
The Court's Reasoning
The Court explained that the prior transfers to petitioners' predecessors-in-interest and the eventual sale of the subject property to petitioners constitute the very chain of transactions that would be collaterally attacked if it upheld the jurisdiction of the DAR Regional Director and the DAR Secretary.
It stated that an undue expansion of the jurisdiction of DAR under the guise of liberally interpreting agrarian laws should not be permitted when Presidential Decree No. 1529 is clear. When the law is clear and free from any doubt or ambiguity, there is no room for construction or interpretation. The Court noted that the liberal interpretation of agrarian laws in favor of the grantee arises only when there is ambiguity.
The Court acknowledged the vital role of farmers and the agricultural sector, and that agrarian reform is anchored on the constitutional mandate to promote social justice. However, it held that recognition of this contribution does not justify disregarding statutes and principles governing the administration of justice. Citing Heirs of Lorenzo Buensuceso v. Perez, it underscored that for a cancellation or forfeiture to take place, the proper procedures must be observed and a final judgment rendered. The Court said there must be a balance between the rights of the farmers and the rights of the landowners.
Because the respondents failed to avail of the proper remedy, their petition for reallocation was dismissed without prejudice to the filing of the appropriate petition to assail the validity of the issuance of TCT No. 363864.
Source: Supreme Court decision in G.R. No. 276299, penned by Associate Justice Jhosep Y. Lopez.
This report summarizes a public Supreme Court decision and is not legal advice.