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JurisprudenceG.R. No. 261059 -

G.R. No. 261059 - ADRIANO S. LORENZO, SR., JOSE D. FLORES III, REPRESENTED BY HIS FATHER, JOSE R. FLORES, JR., AND CARLOS S. FLORES, VS. DOMINADOR M. LIBUNAO, EVAGRIO S. LIBUNAO, NOE S. LIBUNAO, MAYO S. LIBUNAO, AND DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD (DARAB),*. - Supreme Court E-Librar

Cited Laws

RA 6657RA 9700RA 6657,RA 9700,
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TL;DR — Ruling

The petition is unmeritorious.

Decision

Ruling

accordingly affirmed the PARAD's findings. It ruled that without any concrete proof of the alleged fraud in the processing and issuance of the emancipation patents and titles to respondents, they shall remain valid. [9] Subsequently, the DARAB issued its Resolution dated October 28, 2019 denying petitioners' Motion for Reconsideration for want of jurisdiction. According to the DARAB, the exclusive original jurisdiction to resolve cases involving the cancellation of titles issued under any agrarian reform program has already been transferred to the DAR Secretary or his authorized representative. [10] Ruling of the CA In its Decision [11] dated June 30, 2021, the CA denied the petition for review. It ruled that the DARAB correctly divested itself of jurisdiction to rule upon the case in view of the passage of Republic Act No. (RA) 9700, [12] which transferred the exclusive and original jurisdiction of all cases involving cancellation of emancipation patents, certificate of land ownership award and titles to the DAR Secretary. It also noted that the DARAB in fact had no jurisdiction to take on petitioners' appeal because, at the time petitioners filed their appeal on November 20, 2009, RA 9700 was already in force and in effect. [13] Hence, petitioners filed the present petition [14] raising the following issues: Issues WHETHER OR NOT THE HONORABLE COURT OF APPEALS, PARAD[,] AND DARAB ERRED IN NOT APPRECIATING THE EVIDENCE OF THE PETITIONERS; x x x WHO BETWEEN THE PETITIONERS AND RESPONDENTS ARE QUALIFIED TO BECOME BENEFICIARIES OF THE LAND IN QUESTION; WHETHER OR NOT THE x x x EMANCIPATION PATENT NO. 00751354, EMANCIPATION PATENT NO. 00751355, EMANCIPATION PATENT NO. 00751356, EMANCIPATION PATENT NO. 00751357, IN THE NAME OF EVAGRIO S. LIBUNAO, DOMINADOR LIBUNAO, NOE S. LIBUNAO[,] AND MAYO LIBUNAO COULD BE CANCELLED. [15] Essentially, petitioners aver that the PARAD erred in affirming the emancipation patents and titles issued to respondents notwithstanding that petitioners, and not respondents, have been in actual and continuous possession of the subject land. [16] Our Ruling The petition is unmeritorious. At the outset, while petitioners do not raise this as an issue, the Court deems it necessary to emphasize that the CA correctly affirmed the DARAB's Resolution divesting itself of jurisdiction in view of the enactment of RA 9700. Specifically, Section 9 of RA 9700 amending Section 24 of RA 6657 [17] provides: SEC. 24. Award to Beneficiaries. x x x x x x x x All cases involving the cancellation of registered emancipation patents, certificates of land ownership award, and other titles issued under any agrarian reform program are within the exclusive and original jurisdiction of the Secretary of the DAR. As the CA aptly ruled: [I]t may be well to state that at the time the instant complaint for cancellation was filed in July 2005, the jurisdictional setup was that the DARAB will take cognizance of cases that involve the issuance, correction and c