DARAB Jurisdiction Over Annulment of Land Sales Under CARP Coverage

The Supreme Court, in Department of Agrarian Reform v. Robles (G.R. No. 190482, December 9, 2015), clarified the scope of the Department of Agrarian Reform Adjudication Board's (DARAB) jurisdiction over petitions to annul deeds of sale involving agricultural lands. The ruling is significant for landowners, buyers, and practitioners because it settles when DARAB—rather than regular courts—has authority over disputes involving the sale of agricultural property covered by the Comprehensive Agrarian Reform Program (CARP).

The Facts

Eduardo Reyes owned agricultural lands in Magdalena, Laguna, covered by two Transfer Certificates of Title totaling over 200,000 square meters. In April 1997, he sold portions of these properties to six buyers. The deeds of absolute sale were registered in May 2005, and new titles were issued in the buyers' names.

In May 2006, the Department of Agrarian Reform (DAR) filed a petition before the Provincial Agrarian Reform Adjudicator (PARAD) seeking to annul the deeds of sale and cancel the titles. DAR alleged the sales were executed without the required clearance under DAR Administrative Order No. 01-89, violating Section 6 of Republic Act No. 6657 (the Comprehensive Agrarian Reform Law).

The buyers moved to dismiss, arguing DARAB lacked jurisdiction. The Provincial Adjudicator denied the motion, but the Court of Appeals reversed, holding that DARAB's jurisdiction requires a tenancy relationship or that the land be under DAR's administration. The CA dismissed DAR's petition for lack of jurisdiction.

The Issue

The sole issue was whether DARAB has jurisdiction over a petition for annulment of deeds of absolute sale and cancellation of titles involving lands under the administration and disposition of DAR.

The Ruling

The Supreme Court reversed the Court of Appeals and ruled in favor of DAR. The Court held that DARAB has jurisdiction over the petition.

The Court explained that jurisdiction is determined by the material allegations in the petition and the character of the relief prayed for—not by the defenses raised. While the petition did not allege a tenancy relationship, it was anchored on the absence of DAR clearance for the sale, which involves the implementation of agrarian laws.

The Court distinguished between "agrarian disputes" (which require a tenancy relationship) and "agrarian reform matters" (a broader category). The Court refused to restrict DARAB's jurisdiction only to tenancy disputes, noting that the law vests DAR with primary jurisdiction to determine and adjudicate agrarian reform matters.

Crucially, the Court applied its earlier ruling in Sarne v. Maquiling, which held that the phrase "agricultural lands under the coverage of the CARP" includes all private lands devoted to or suitable for agriculture. A notice of coverage is not required for DARAB to exercise jurisdiction over cases involving the sale or alienation of such lands under the DARAB Rules of Procedure.

The Court also noted that DAR Memorandum Circular No. 02-01 expressly directed that petitions for annulment of deeds of conveyance executed in violation of Section 6, paragraph 4 of RA 6657 be filed before the Provincial Adjudicator. This referral made the case an "agrarian reform matter" within DARAB's jurisdiction.

Practical Takeaways

• DARAB jurisdiction is broader than tenancy disputes. DARAB can hear cases involving "agrarian reform matters," not just "agrarian disputes" requiring a landlord-tenant relationship.
• Notice of coverage is not a jurisdictional requirement. For cases involving the sale or alienation of agricultural lands under CARP coverage, DARAB has jurisdiction even without a prior notice of coverage.
• All private agricultural lands are potentially covered. Under RA 6657, CARP covers all private lands devoted to or suitable for agriculture, regardless of the commodity produced or tenurial arrangement.
• Buyers of agricultural land should obtain DAR clearance. Sales of agricultural land without the required DAR clearance under Administrative Order No. 01-89 risk annulment proceedings before DARAB.
• Jurisdiction is determined by the allegations in the petition. A respondent cannot defeat DARAB jurisdiction by raising defenses like lack of tenancy or absence of notice of coverage.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.