Cited Laws
TL;DR — Ruling
WHEREFORE, premises considered, the appeal is hereby GRANTED . The Decision appealed from is REVERSED and SET ASIDE . The complaint against [respondent] is ordered DISMISSED .” [4] The challenged Resolution denied reconsideration of the Decision.
WHEREFORE, premises considered, the appeal is hereby GRANTED . The Decision appealed from is REVERSED and SET ASIDE . The complaint against [respondent] is ordered DISMISSED . [4] The challenged Resolution denied reconsideration of the Decision. The Facts The CA narrates the facts in this wise: The agricultural lot in question, designated as Lot No. 26, is situated at Poblacion, San Rafael, Bulacan, and covered by TCT No. RT-6304. Along with another parcel of land with an area of 2½ hectares, it was originally owned by Maria Lopez Caluag ( or Caluag ), who is now deceased. The original tenant-tiller of this agricultural land was the late Aqui[li]no Villena, husband of [respondent], Susana Mag[-I]sa Villena ( or Susana ). The tenancy relationship dated back to 1946 and continued even after the demise of Aquilino through his surviving spouse, Susana. In 1957, upon the instruction of Caluag, the house of Susana was transferred to the subject lot, because Caluag had given Susana a portion thereof with an area of 1000 square meters as [home lot] and seedbed. Since then, Susana had been in peaceful possession thereof until 1987 when a case for ejectment was filed against her by [petitioners] Eugenio Bautista, Romeo Cruz and Carmencita B. Cruz x x x. [5] The ejectment case did not prosper. Thus, at the Regional Trial Court (RTC) of Bulacan on March 26, 1990, petitioners filed against respondent an action for quieting of title and recovery of possession. [6] The trial court ruled in favor of petitioners, prompting respondent to appeal to the CA. Ruling of the Court of Appeals Reversing the trial court, the appellate court ruled that as tenant of the previous owner of the land, respondent was entitled to a home lot and the right to maintain a house thereon. [7] It also opined that since the case involved the right to continue and enjoy the home lot, jurisdiction belonged to the Department of Agrarian Reform Adjudication Board (DARAB), not to the trial court. [8] Hence, this Petition. [9] The Issue The sole issue raised by petitioners for our consideration is as follows: x x x [W]hether or not this case falls under the ambit of the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB) pursuant to Executive Order 129-A. [10] The Courts Ruling The Petition has no merit. Sole Issue: Jurisdiction of the DARAB The doctrine of primary jurisdiction precludes the courts from resolving a controversy over which jurisdiction has initially been lodged with an administrative body of special competence. [11] For agrarian reform cases, jurisdiction is vested in the Department of Agrarian Reform (DAR); more specifically, in the Department of Agrarian Reform Adjudication Board (DARAB). Executive Order 229 [12] vested the DAR with (1) quasi-judicial powers to determine and adjudicate agrarian reform matters; and (2) jurisdiction over all matters involving the implementation of agrarian reform, except those falling under the ex
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