GR L 55393; (October, 1991) (Digest)
G.R. No. L-55393 October 28, 1991
FAGEL TABIN AGRICULTURAL CORPORATION, represented by ANTONIO FAGEL, SR., petitioner, vs. HON. EMILIO A. JACINTO, Judge of the Court of Agrarian Relations, HON. CONRADO F. ESTRELLA, Minister of Agrarian Reform, and BERNARDINO AGUHOD, DEMETRIO DALIAN, ET AL., respondents.
FACTS
Petitioner Fagel Tabin Agricultural Corporation owns a 165-hectare agricultural land in Davao City. In 1977, the Ministry of Agrarian Reform (MAR) issued 35 Certificates of Land Transfer (CLTs) covering 43.51 hectares of the property, placing these portions under Operation Land Transfer pursuant to Presidential Decree No. 27. The petitioner contended that its land was primarily devoted to coconut and rubber, not rice or corn, and was therefore outside the scope of P.D. No. 27, which applied only to tenanted lands primarily devoted to rice and corn.
The petitioner filed a complaint for the declaration of nullity of the CLTs before the Court of Agrarian Relations (CAR). The respondents, including the MAR officials, moved for dismissal, arguing that under Section 12(b) of P.D. No. 946, matters involving the administrative implementation of land transfer, including the issuance and cancellation of CLTs, were exclusively cognizable by the Secretary of Agrarian Reform. The CAR agreed and dismissed the complaint for lack of jurisdiction.
ISSUE
Whether the Court of Agrarian Relations correctly dismissed the petitioner’s complaint for lack of jurisdiction over the subject matter.
RULING
Yes, the dismissal was correct. The Supreme Court upheld the CAR’s ruling that it lacked jurisdiction. The legal logic is grounded on the explicit and unambiguous language of Section 12(b) of P.D. No. 946, which reorganized the agrarian courts. This provision expressly enumerates specific matters that fall under the exclusive original jurisdiction of the Secretary of Agrarian Reform, not the CAR. These enumerated matters include the “classification and identification of landholdings” and the “issuance, recall or cancellation of certificates of land transfer.”
The petitioner’s action, which sought to nullify the CLTs on the grounds of improper land classification and illegal issuance, directly falls within these enumerated administrative functions. Since the statute is clear, it must be applied as written, without judicial addition or subtraction. The proper recourse for the petitioner was to seek relief through the administrative machinery of the Ministry of Agrarian Reform, not through the courts. Furthermore, the Court noted the petition had been rendered moot and academic by the passage of the Comprehensive Agrarian Reform Law ( R.A. No. 6657 ), which expanded coverage to all agricultural lands regardless of crop.