On April 24, 1992, Virginia P. Estrella, the mother of the herein petitioners and respondents, died leaving behind parcels of agricultural lands covered by Emancipation Patents, to wit:a. Emancipation Patent No. 445226;Thereafter, the respondents sought for the partition of the abovecited real properties. However, the petitioners, Spouses Teodora Carpio and Teofilo Carpio, refused to agree with the partition of the estate, alleging that they are the exclusive owners of the parcel of land covered by Emancipation Patent No. 445229, having purchased the same from landowner Luis T. Bautista in 1991. Moreover, the petitioners also claim tenancy right to the exclusion of the respondents over the land covered by the said emancipation patent.
b. Emancipation Patent No. 445227;
c. Emancipation Patent No. 445228;
d. Emancipation Patent No. 445229; and
e. Emancipation Patent No. 445230.
Efforts toward amicable settlement having proved futile, the respondents, on February 14, 1995, instituted an action for Annulment of Sale of Land covered by Emancipation Patent No. 445229, with Prayer for Declaration of Rights of Tenancy with the Department of Agrarian Reform Adjudication Board (DARAB), Region III, Malolos, Bulacan.
Consequently, on June 28, 1996, the Provincial Adjudicator, claiming lack of jurisdiction, dismissed the aforementioned complaint for annulment of sale filed by the respondents.
Aggrieved, the respondents interposed an appeal from the said decision of the DAR Provincial Adjudication Board to the DARAB stationed in Quezon City.
On December 28, 2000, the DARAB rendered the assailed decision reversing and setting aside the decision of the DAR Provincial Adjudication Board, the dispositive portion of which provides as follows:WHEREFORE, premises considered, the appealed decisions are hereby REVERSED and SET ASIDE and a new decision is rendered as follows:
1. Declaring that the Board a quo has jurisdiction over the issues raised in these twin cases;
2. Declaring the Deed of Absolute Sale and the Deed of Conveyance executed by former landowner Luis Bautista in favor of the herein Respondents-Appellees involving the landholding covered by the Emancipation Patents issued to Virginia P. Estrella as null and void;
3. Directing the partition of the subject landholdings with the assistance of the Municipal Agrarian Reform Officer (MARO) concerned, the same to be in accordance with then Ministry Memorandum Circular No. 19, Series of 1978 and/or other circulars relevant thereto implementing Presidential Decree No. 27 on the subject Rules and Regulations in case of Death of a Tenant-Beneficiary; and
4. Directing that in case of disagreement, the matter must be decided by the DAR Regional Office, it being purely administrative function under the Office of the DAR Secretary.
From this decision, a motion for reconsideration was filed, but the same was denied. x x x
1. Whether or not the Court of Appeals erred in holding that the dispute between the parties is within the jurisdiction of the DARAB.
2. Whether or not the Court of Appeals committed clear and palpable errors in not finding that petitioners have been tenants over the subject landholding; and that the sale of the subject lot to them is valid, thereby deviating from and disregarding established Supreme Court decisions enjoining Courts not to overlook or misinterpret important facts and circumstances supported by clear and convincing evidence on record and which are of great weight and value to change the results of the case and arrive at a just, fair and objective decision.3
Section 1. Primary and Exclusive Original and Appellate Jurisdiction. - The Board shall have primary and exclusive jurisdiction, both original and appellate, to determine and adjudicate all agrarian disputes involving the implementation of the Comprehensive Agrarian Reform Program (CARP) under Republic Act No. 6657, Executive Order Nos. 228, and 129-A, Republic Act No. 3844 as amended by Republic Act No. 6389, Presidential Decree No. 27 and other agrarian laws and their implementing rules and regulations. Specifically, such jurisdiction shall include but not be limited to cases involving the following:x x x x
c) The annulment or cancellation of lease contracts or deeds of sale or their amendments involving lands under the administration and disposition of the DAR or LBP;
x x x x
e) Those involving the sale, alienation, mortgage, foreclosure, pre-emption and redemption of agricultural lands under the coverage of the CARP or other agrarian laws;
f) Those involving the issuance, correction and cancellation of x x x Emancipation Patents (EPs) which are registered with the Land Registration Authority; x x x
The Department of Agrarian Reform Adjudication Board (DARAB) is vested with primary and exclusive jurisdiction to determine and adjudicate agrarian reform matters, including all matters involving the implementation of the agrarian reform program. Thus, when a case is merely an incident involving the implementation of the Comprehensive Agrarian Reform Program (CARP), then jurisdiction remains with the DARAB, and not with the regular courts.
x x x x
x x x [J]urisdiction should be determined by considering not only the status or relationship of the parties but also the nature of the issues or questions that is the subject of the controversy. Thus, if the issues between the parties are intertwined with the resolution of an issue within the exclusive jurisdiction of the DARAB, such dispute must be addressed and resolved by the DARAB.5
Note the allegations in the complaint, to wit:
x x x x
4. That plaintiffs sought for partition of the properties above-cited however, defendants Sps. Teodora Carpio and Teofilo Carpio [herein petitioners] refused to agree with [the] partition of the estate giving reasons thereof that they are the exclusive owners of the parcels of land covered by Emancipation Patent No. 445229 (Annex "A"), having purchased the same from landowner Luis Bautista in the year 1991;
5. That defendant also claims tenancy right to the exclusion of the herein plaintiffs over the land covered by EP No. 445229 despite the fact that it was their mother who was the real tenant of the lands subject matter of this case;
6. That the sale entered into by defendants Spouses Teodora Carpio and Teofilo Carpio with the landowner Luis Bautista is null and void because the land was already titled to [the] deceased mother of both plaintiffs and defendants at the time of sale and that the owner thereof has been already divested ownership of the land by operation of law;
7. That defendants cannot claim exclusive right of tenancy over the land subject matter of this action to the exclusion of the other heirs because the right to till the lands belong to all heirs;
x x x x6
x x x It bears stressing that in a petition for review on certiorari, the scope of this Court's judicial review of decisions of the Court of Appeals is generally confined only to errors of law, and questions of fact are not entertained. We elucidated on our fidelity to this rule, and we said:Thus, only questions of law may be brought by the parties and passed upon by this Court in the exercise of its power to review. Also, judicial review by this Court does not extend to a reevaluation of the sufficiency of the evidence upon which the proper x x x tribunal has based its determination.
It is aphoristic that a re-examination of factual findings cannot be done through a petition for review on certiorari under Rule 45 of the Rules of Court because as earlier stated, this Court is not a trier of facts; it reviews only questions of law. The Supreme Court is not duty-bound to analyze and weigh again the evidence considered in the proceedings below. x x x 8
x x x Accordingly, when said Decree took effect on October 21, 1972, the DAR field office conducted their respective official duties and responsibilities such as, but not limited to, the classification and identification of the landholding, identification of tenant-farmers and landowners and determination of their tenancy relationship; parcellary mapping; determination of the total production of Certificate of Land Transfer in cases outside the purview of Presidential Decree No. 816 x x x. Obviously, therefore, said DAR field personnel concerned had undergone the process in the determination of the tenancy relationship between the late Virginia P. Estrella with that of landowner Luis Bautista. Otherwise, the DAR Regional Office could not have issued the corresponding Emancipation Patents in the name of Virginia P. Estrella if the latter was found out (sic) not to be a bona fide tenant in accordance with DAR Memorandum dated September 15, 1976 on the subject: Revised and Detailed Operation Procedures on the Issuance of Emancipation Patents. In fact, the receipt of lease rentals dated March 30, 1978, March 31, 1979 and March 24, 1980 were issued by the landowner in the name of Virginia P. Estrella (p. 102, Rollo). In other words, these evidences (sic) show that Virginia P. Estrella was really the duly recognized tenant by landowner Luis Bautista. The real status, therefore, of [herein petitioners] were as immediate members of the farm household of Virginia P. Estrella x x x. Moreover, this Board takes note that the Deed of Absolute Sale dated December 22, 1991 did not indicate any previous agreement to the effect that there was an agreement to sell by installment. Rather, it was a plain document of a direct sale effected only in 1991, while the Emancipation Patents issued to tenant-beneficiary Virginia P. Estrella were dated December 14, 1989. x x x9
x x x findings of facts of quasi-judicial bodies x x x affirmed by the Court of Appeals in due course, are conclusive on this Court, which is not a trier of facts.
x x x x
x x x Findings of fact of administrative agencies and quasi-judicial bodies, which have acquired expertise because their jurisdiction is confined to specific matters, are generally accorded not only respect, but finality when affirmed by the Court of Appeals. Such findings deserve full respect and, without justifiable reason, ought not to be altered, modified or reversed.11
* Designated as an additional member in lieu of Associate Justice Jose Catral Mendoza, per Special Order No. 842 dated June 3, 2010.
1 Penned by Associate Justice Amelita G. Tolentino, with Associate Justices Eloy R. Bello, Jr. and Magdangal M. de Leon, concurring; rollo, pp. 74-83.
2 Penned by Associate Justice Amelita G. Tolentino, with Associate Justices Lucas P. Bersamin (now a member of this Court) and Magdangal M. de Leon, concurring; id. at 88-89.
3 Rollo, pp. 24-25.
4 G.R. No. 163285, February 27, 2008, 547 SCRA 30.
5 Id. at 32, 34. (Emphasis supplied.)
6 Rollo, pp. 36-37.
7 G.R. No. 168475, July 4, 2007, 526 SCRA 440.
8 Id. at 460-461. (Emphasis supplied.)
9 DARAB Decision, rollo, pp. 60-61.
10 G.R. No. 160233, August 8, 2007, 529 SCRA 487.
11 Id. at 494, 499. (Emphasis supplied.)