G.R. Nos. 155322-29; June 27, 2012
Bases Conversion Development Authority vs. Provincial Agrarian Reform Officer of Pampanga, et al.

FACTS

The Bases Conversion Development Authority (BCDA), a government-owned corporation created under Republic Act No. 7227 , became the owner of lands within the Clark Special Economic Zone (CSEZ) by virtue of Proclamation No. 163, which transferred said lands from the Republic of the Philippines. The titles, TCT Nos. 18247-R and 18257-R, were registered in the name of the Republic. Subsequently, BCDA discovered that the Department of Agrarian Reform (DAR) had issued Certificates of Land Ownership Award (CLOAs) to several private respondents over portions of these same lands in 1998. BCDA then filed petitions before the Regional Trial Court (RTC) to nullify these CLOAs and to direct the Register of Deeds to cancel the annotations on the titles.
The RTC dismissed BCDA’s petitions. It ruled that the issuance of the CLOAs was an agrarian reform matter falling under the primary and exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). The court held that BCDA should have first exhausted administrative remedies by filing a case before the DARAB, not the RTC. BCDA filed a motion for reconsideration, which was denied, prompting this petition for review on certiorari.

ISSUE

Whether the Regional Trial Court correctly dismissed the petitions on the ground of lack of jurisdiction, holding that the case involved an agrarian reform matter within the exclusive jurisdiction of the DARAB.

RULING

No. The Supreme Court reversed the RTC’s order and reinstated the petitions. The core legal logic is that jurisdiction is conferred by law and is determined by the allegations in the complaint and the nature of the relief sought. BCDA’s petitions essentially sought the nullification of the CLOAs and the cancellation of their annotations on the ground that the subject lands were part of the CSEZ, owned by the Republic and transferred to BCDA, and were thus expressly excluded from the coverage of the Comprehensive Agrarian Reform Program (CARP) by Proclamation No. 163 and the governing law, R.A. No. 7227 .
The Court held that the case did not involve an agrarian dispute—which would fall under DARAB’s jurisdiction—but a question of ownership and the validity of the CLOAs issued over lands that were legally inalienable and non-disposable. The principal issue was whether DAR had the authority to issue CLOAs over properties that had already been withdrawn from CARP coverage and vested in BCDA by a special law. This is a judicial question involving the interpretation of laws and proclamations, which is within the regular courts’ jurisdiction. The RTC therefore erred in dismissing the case for lack of jurisdiction; it should have proceeded to hear the case on its merits.