G.R. No. 132759 & 132866. October 25, 2005.
Alejandro Danan, et al. and the Department of Agrarian Reform Adjudication Board (DARAB), Petitioners, vs. The Honorable Court of Appeals and Estrella Arrastia, Respondents.

FACTS

The petitioners, members of the Aniban ng mga Manggagawa sa Agrikultura (AMA), entered and cultivated a 300-hectare landholding in Lubao, Pampanga, owned by the Arrastia heirs, including respondent Estrella Arrastia. This entry in 1986 was based on a joint resolution they signed and was endorsed by the provincial governor, but it was done without the consent of the landowners. This led to a violent confrontation in 1988. The AMA filed a case (DARAB Case No. 0001) seeking to continue farming, but the DARAB denied their motion for authority to cultivate, a decision which became final in 1989.
Subsequently, Arrastia filed an action for violation of agrarian laws. The DARAB, in a later consolidated case (DARAB Case No. 1551), ruled in favor of the farmer-claimants, ordering the coverage of the land under CARP and its distribution to them. The Court of Appeals reversed this DARAB decision, holding that the petitioners were not bona fide tenants or farmers on the land and that the DARAB had no jurisdiction because no tenurial relationship was established.

ISSUE

The core issue is whether the DARAB had jurisdiction over the case, which hinges on whether a tenurial relationship existed between the landowner and the farmer-claimants to bring the dispute within the ambit of agrarian reform laws.

RULING

The Supreme Court affirmed the Court of Appeals and ruled that the DARAB had no jurisdiction. Jurisdiction of the DARAB is limited to agrarian disputes, which by definition under Republic Act No. 6657 require a tenurial arrangement between the parties, such as that of landowner and tenant or agricultural lessor and lessee. The Court emphasized that the mere cultivation of land by itself does not create a tenurial relationship.
The legal logic is clear: for the DARAB to have jurisdiction, the dispute must arise from an agrarian relationship. Here, the petitioners entered the land without the consent of the landowners. Their occupation was an act of force and intrusion, not a product of any agreement, leasehold, or tenancy arrangement. The finality of the earlier DARAB order denying their motion to cultivate further negated any claim of a lawful tenurial link. Since no such relationship was established, the dispute was not agrarian in nature. Consequently, the DARAB had no authority to order the land’s coverage under CARP. The proper remedy for the landowners was an action for ejectment or recovery of possession in the regular courts, not an agrarian reform proceeding.