Concha vs Rubio G.R. No. 162446, Mar. 29, 2010 617 SCRA 223

Fact: A subject landholding was placed under the Compulsory Acquisition Scheme of the CARP of the government. A Notice of Coverage was sent to the landowners. MARO of Tiaong, Quezon, named the Petitioners beneficiaries. Respondents filed a complaint for declaration of their tenancy and their identification as beneficiaries and for disqualification of the petitioners to become beneficiaries over the subject landholding. They alleged that they are the tenants thereof and have not relinquished their rights over the same, as they returned the monetary awards given by the landowners. MARO pursued the coverage. The petitioners herein were identified as qualified farmer-beneficiaries where CLOA were issued in their favor.  Respondents, on the other hand, were paid of their disturbance compensation. They now, however, question the validity and legality of the institution of the petitioners as beneficiaries over the subject landholding. Respondents together with the landowners filed another case for annulment of CLOAs and prayer for Preliminary Injunction and Restraining Order. The Office of the PARAD rendered a Decision dismissing the case in favor of the petitioners. The PARAD ruled that respondents had waived their rights as tenants and as farmer-beneficiaries of the Department of Agrarian Reform (DAR) program, In addition, the PARAD ruled that it had no authority to rule on the selection of farmer-beneficiaries, as the same was a purely administrative matter under the jurisdiction of the DAR. Respondents filed a Notice of Appeal of the PARAD Decision. DARAB setting aside the PARAD Decision, ordered the Register of Deeds for the Province of Quezon to cancel the Certificates of Land Ownership Award issued to petitioners, and the MARO and PARO to generate and issue new Certificates of Land Ownership Award in favor of the Respondents. Aggrieved, petitioners filed a Motion for Reconsideration of the DARAB Decision which the it denied. Petitioners then appealed to the CA who ruling in favor of petitioners but subsequently reversed its decision in favor of the respondents. Hence, herein petition, with petitioners raising a sole assignment of error, to wit:

Issue: whether the honorable DARAB is clothed with jurisdiction to resolve the issue involving the identification and selection of qualified farmer-beneficiaries of a land covered by the CARP

Held: No, that the DARAB is not clothed with the power or authority to resolve the issue involving the identification and selection of qualified farmer-beneficiaries since the same is an Agrarian Law Implementation case, thus, an administrative function falling within the jurisdiction of the DAR Secretary. The Court was categorically ruled that the identification and selection of CARP beneficiaries are matters involving strictly the administrative implementation of the CARP, a matter exclusively cognizable by the Secretary of the Department of Agrarian Reform, and beyond the jurisdiction of the DARAB. That the administrative function of the DAR is manifest in Administrative Order No. 06-00, which provides for the Rules of Procedure for Agrarian Law Implementation Cases. Under said Rules of Procedure, the DAR Secretary has exclusive jurisdiction over identification, qualification or disqualification of potential farmer-beneficiaries. Based on the foregoing, the conclusion is certain that the DARAB had no jurisdiction to identify who between the parties should be recognized as the beneficiaries of the land in dispute, as it was a purely administrative function of the DAR.

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