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Agrarian Land Dispute Ruling 2016

The Supreme Court ruled that: 1) The heirs of Alfredo Restrivera did not have legal standing to challenge the award of an 8.839-hectare agricultural land to farmer-beneficiaries under the Comprehensive Agrarian Reform Program, as they could not claim current ownership and any interest subject to succession. 2) The Agrarian Adjudication Board did not have jurisdiction over the heirs' petition for cancellation and reconveyance of the land, as there was no existing agrarian dispute or tenancy relationship between the parties. Determining land coverage and farmer-beneficiary rights under the agrarian reform program falls under the exclusive jurisdiction of the Department of Agrarian Reform.

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528 views2 pages

Agrarian Land Dispute Ruling 2016

The Supreme Court ruled that: 1) The heirs of Alfredo Restrivera did not have legal standing to challenge the award of an 8.839-hectare agricultural land to farmer-beneficiaries under the Comprehensive Agrarian Reform Program, as they could not claim current ownership and any interest subject to succession. 2) The Agrarian Adjudication Board did not have jurisdiction over the heirs' petition for cancellation and reconveyance of the land, as there was no existing agrarian dispute or tenancy relationship between the parties. Determining land coverage and farmer-beneficiary rights under the agrarian reform program falls under the exclusive jurisdiction of the Department of Agrarian Reform.

Uploaded by

aisah
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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G.R. No.

185312, December 01, 2016


NICANOR MALABANAN vs. HEIRS OF ALFREDO RESTRIVERA
Facts:

The disputed property is an 8.839-hectare agricultural land situated in Potrero, Bancal,


Carmona, Cavite. It used to be registered under the name of Alfredo Restrivera.

The PCGG then transferred the above property to the Department of Agrarian Reform
(DAR) for distribution to qualified farmer-beneficiaries of the Comprehensive Agrarian
Reform Program (CARP).

In February 2002, DAR awarded the land to petitioners. Invoking their preferential right
as farmer-beneficiaries under Section 22 of Republic Act No. (R.A.) 6657, 11 respondents
filed before the Adjudication Board for Region IV a Petition for Cancellation of CLOA.

Issues:

(1) whether petitioners have the legal personality to assail the distribution of the subject
land under the agrarian reform program; and

(2) whether the agrarian adjudicator has jurisdiction over a petition for cancellation of title
and reconveyance of agricultural land sequestered by or surrendered to the PCGG.

Rulings:

1. Respondents have no legal standing to assail the award of the subject land to
petitioners.

Fortich v. Corona40 ordains that farmer-beneficiaries who are not approved awardees of
CARP have no legal standing to question the exclusion of an agricultural land from CARP
coverage.

Respondents cannot rely solely on their father's title to assert ownership over the subject
land. A title is merely evidence of ownership of the particular property described therein.
Ownership is not the same as a certificate of title.44

At this point, respondents cannot claim ownership of the land, or any interest therein that
could have been the subject of succession. Concomitantly, they have no legal standing
to challenge the propriety of its distribution under CARP by virtue of their interest as
Alfredo's compulsory heirs.

2. DARAB has no jurisdiction over the petition filed by respondents.

It is settled that for DARAB to have jurisdiction over a case, there must be an agrarian
dispute or tenancy relationship existing between the parties.
In this case, respondents have not alleged any tenurial relationship with petitioners.
Rather, their petition is centered on their supposed preferential right as farmer-
beneficiaries and the suitability of the land for CARP coverage. These are matters falling
under the primary and exclusive jurisdiction of DAR, which is supposed to determine and
adjudicate all matters involving the implementation of agrarian reform.

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