Heirs of Nicolas Jugalbot, et al. vs. Heirs of Virginia A. Roa, et al. G.R. No.

170346 (March 12, 2007)

Facts: An Emancipation Patent (EP) was issued to Nicolas Jugalbot based on the latter's claim that he was the tenant of the
subject property located at Brgy. Lapasan, Cagayan de Oro City, registered in the name of Virginia A. Roa under TCT No.
T-11543. The property was originally registered in the name of Marcelino Cabili from whom Virginia A. Roa purchased
the same sometime in 1966.

The heirs of Virginia A. Roa, herein private respondents, filed before the DARAB Provincial Office of Misamis Oriental a
Complaint for cancellation of title (TCT No. E-103), Recovery of Possession and Damages against Nicolas Jugalbot.

A Decision was rendered dismissing private respondents' complaint and upholding the validity of the Emancipation Patent.
Private respondent filed a motion for reconsideration but was denied.

On appeal, the DARAB (Department of Agrarian Reform Adjudication Board) Central Office affirmed the Provincial
Adjudicator's decision on the sole ground that private respondents' right to contest the validity of Nicolas Jugalbot's title
was barred by prescription.

The DARAB denied private respondents' motion for reconsideration, hence they filed a petition for review before the Court
of Appeals which was granted. The appellate court reversed the Decision and Resolution of the DARAB Central Office on
the following grounds: (1) the absence of a tenancy relationship; (2) lack of notice to Virginia Roa by the DAR; (3) the area
of the property which was less than one hectare and deemed swampy, rainfed and kangkong-producing: and (4) the
classification of the subject property as residential, which is outside the coverage of P.D. No. 27.

Issue: Whether the DARAB has the authority to rule over the land dispute

Ruling: Yes.

Section 50 of the CARL (Comprehensive Agrarian Reform Law) bestows upon the DAR quasi-judicial powers:

SEC. 50. Quasi-Judicial Powers of the DAR. – The DAR is hereby vested with primary jurisdiction to determine and
adjudicate agrarian reform matters and shall have exclusive original jurisdiction over all matters involving the
implementation of agrarian reform, except those falling under the exclusive jurisdiction of the Department of Agriculture
(DA) and the Department of Environment and Natural Resources (DENR).

Furthermore, jurisdiction over agrarian disputes lies with the DARAB. Section 3(d) of the CARL defines an agrarian dispute
as follows:

(d) Agrarian dispute refers to any controversy relating to tenurial arrangements, whether leasehold, tenancy, stewardship
or otherwise, over lands devoted to agriculture, including disputes concerning farmworkers associations or representation
of persons in negotiating, fixing, maintaining, changing or seeking to arrange terms or conditions of such tenurial
arrangements.

It includes any controversy relating to compensation of lands acquired under this Act and other terms and conditions of
transfer of ownership from landowners to farmworkers, tenants and other agrarian reform beneficiaries, whether the
disputants stand in the proximate relation of farm operator and beneficiary, landowner and tenant, or lessor and lessee.