Union Bank of the Philippines vs.

The Honorable Regional Agrarian Reform Officer

G.R No. 200369, March 1, 2017
Facts:
A property owned by Union Bank covered by TCT No. T-137846 and T-156610 was offered by the
same to DAR through the Voluntary Offer to Sell (VOS) arrangement under te Comprehensive Agrarian
Reform Program (CARP) of the government. After inspection of the properties by DAR and the LBP, a just
compensation was offered by DAR. The petitioner did not agree with the valuation; thus the DAR
Regional Director requested LBP to open trust accounts in the name of Union Bank.

The DAR started issuing CLOAs in the name of private respondent as Agrarian Reform
beneficiaries for the land covered by the TCT-156610 and transferred the TCT-137846 was transferred to
the Republic of the Philippines. The petitioner then filed a motion to withdraw voluntary offer to sell on
property from CARP Coverage in the land valuation proceedings for the land covered b the TCT No. T-
156610 pending before RARAD. The Petitioner also filed petitions for cancellation of the CLOAs before
the PARAD which denied such. It filed a motion for reconsideration but it was also denied. Aggrieved,
the petitioner filed a petition before the DARAB which denied such for being premature since Union
Bank’s request for withdrawal of its VOS and exemption from CARP is still pending with the DAR. The
Motion for Reconsideration was likewise denied. The CA also dismissed their petition for review and
held that for the DARAB to have jurisdiction in cases involving cancellation of the CLOAs, there must be
an agrarian dispute between land owners and tenants who are recipients of the CLOAs. The CA found
that there is no evidence showing that petitioner and private respondents agrarian reform beneficiaries
had tenancy relations.

Issue:

Whether or not the DARAB has jurisdiction over petitions for cancellation of Certificates of Land
Ownership Award (CLOAs) involving parties who do not have tenancy relationship.

Ruling:

No, the DARAB has no jurisdiction over petitions for cancellation of CLOAs involving parties who
do not have a tenancy relationship.

The Supreme Court held that for DARAB to acquire jurisdiction over such case, there must be a
prima facie showing that there is a tenurial arrangement or tenancy relationship between the parties.
The records clearly showed that the petitions filed by the Union Bank did not involve agrarian disputes.
And that jurisdiction of a court over the nature and subject matter of an action is conferred by law. In
this case the Executive Order No. 129-A transferred the power to adjudicate agrarian reform cases to
DARAB and the jurisdiction over the implementation of agrarian reform was delegated to DAR Regional
Offices.

Thus, in the absence of a tenancy relationship between Union Bank and private respondents,
the PARAD/DARAB has no jurisdiction over the petitions for cancellation of the CLOAs.