Scribd Logo
Upload

Welcome to Scribd!

  • 55 views

    Magno v. Franciso

    Uploaded by

    Lance Lagman
    This document summarizes a Supreme Court case regarding a dispute over agricultural land between a landowner and two tenants. [1] The landowner filed a complaint for ejectment and unpaid rentals against the tenants. [2] The DAR initially ruled in favor of the landowner but higher courts sided with the tenants, finding issues with the landowner's arguments. [3] The Supreme Court ultimately ruled that the DAR Secretary must first determine if the land is properly part of agrarian reform before the dispute can be fully resolved, as classification of land is under the DAR Secretary's jurisdiction.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Magno v. Franciso

    Uploaded by

    Lance Lagman
    55 views3 pages
    This document summarizes a Supreme Court case regarding a dispute over agricultural land between a landowner and two tenants. [1] The landowner filed a complaint for ejectment and unpaid rentals against the tenants. [2] The DAR initially ruled in favor of the landowner but higher courts sided with the tenants, finding issues with the landowner's arguments. [3] The Supreme Court ultimately ruled that the DAR Secretary must first determine if the land is properly part of agrarian reform before the dispute can be fully resolved, as classification of land is under the DAR Secretary's jurisdiction.

    Original Title

    6. Magno v. Franciso

    Copyright

    © © All Rights Reserved

    Available Formats

    PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    This document summarizes a Supreme Court case regarding a dispute over agricultural land between a landowner and two tenants. [1] The landowner filed a complaint for ejectment and unpaid rentals against the tenants. [2] The DAR initially ruled in favor of the landowner but higher courts sided with the tenants, finding issues with the landowner's arguments. [3] The Supreme Court ultimately ruled that the DAR Secretary must first determine if the land is properly part of agrarian reform before the dispute can be fully resolved, as classification of land is under the DAR Secretary's jurisdiction.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    55 views3 pages

    Magno v. Franciso

    Uploaded by

    Lance Lagman
    This document summarizes a Supreme Court case regarding a dispute over agricultural land between a landowner and two tenants. [1] The landowner filed a complaint for ejectment and unpaid rentals against the tenants. [2] The DAR initially ruled in favor of the landowner but higher courts sided with the tenants, finding issues with the landowner's arguments. [3] The Supreme Court ultimately ruled that the DAR Secretary must first determine if the land is properly part of agrarian reform before the dispute can be fully resolved, as classification of land is under the DAR Secretary's jurisdiction.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 3

    AGRARIAN LAW &

    SOCIAL LEGISLATION

    G.R. No. 168959


    6. Magno v. Francisco
    Date: March 25, 2010 Topic: Quasi-Judicial Powers
    of the DAR
    Ponente: CARPIO,
    Acting C.J.

    DOCTRINE: The DAR is vested with the primary jurisdiction to determine and
    adjudicate agrarian reform matters and shall have the exclusive jurisdiction over all
    matters involving the implementation of the agrarian reform program.

    The DARAB has primary, original and appellate jurisdiction “to determine and
    adjudicate all agrarian disputes, cases, controversies, and matters or incidents
    involving the implementation of the Comprehensive Agrarian Reform Program
    under RA No. 6657, E.O. Nos. 229, 228 and 129-A, R.A. No. 3844as amended by R.A.
    No. 6389, P.D. No. 27 and other agrarian laws and their implementing rules and
    regulations.”

    FACTS
    Petitioner is the owner of a 5.3 hectare lot (lot) which is a portion of an agricultural
    land identified as Lot No. 593 situated in Brgy. San Fernando, Cabiao, Nueva Ecija.
    Petitioner acquired the lot through a Deed of Sale executed by Talens on
    28 July 1972, but the sale was only registered on 3 September 1986. At the
    time of the sale, respondents Gonzalo Francisco and Manuel Lazaro tenanted the
    land and their separate areas of tillage were 2.8 and 2.5 hectares, respectively.

    In the agricultural leasehold contract entered into by petitioner and


    respondents, Manuel Lazaro was obliged to pay a lease rental of 35 cavans during
    the regular season, and 20 cavans during dayatan cropping season. Gonzalo
    Francisco, on the other hand, was required to pay a lease rental of 35 cavans during
    the regular season and 25 cavans during the cropping season.

    Respondents stopped paying the rentals despite petitioner's demands, arguing that
    that they have fully paid the price of the lot under the Barangay Committee on Land
    Productions (BCLP) valuation.

    In 1990, respondents were issued their respective Emancipation Patents (EP). Thus,
    petitioner filed with PARAD of Cabanatuan City a complaint for ejectment and
    collection of lease rentals against respondents. At the time of filing of the complaint,
    respondent Francisco and respondent Lazaro were already in arrears of 155 cavans
    and 145 cavans, respectively.

    The PARAD of Cabanatuan City dismissed the case for lack of merit. On appeal, the
    DARAB reversed the PARADs decision. On further appeal, however, the CA reversed
    the DARAB ruling and reinstated the decision of PARAD. The CA stated that the EPs

    1
    AGRARIAN LAW &
    SOCIAL LEGISLATION

    are public documents and are prima facie evidence of the facts stated therein. The
    EPs are presumably issued in the regular performance of an official duty. The CA
    ruled that petitioner has not presented any evidence showing that the issuance of the
    EPs was tainted with defects and irregularities; hence, they are entitled to full faith
    and credit.

    Petitioner points out that the CA disregarded a significant fact that the land valuation
    came after the issuance of the EPs; hence, the issuance of the EPs was tainted with
    irregularity because it was violative of Section 2 of PD 266.

    Respondents argue that the DAR has not yet submitted the result of the
    administrative determination of the lot in dispute to the DARAB. Respondents
    contend that the DARAB's decision was issued without jurisdiction.

    ISSUE/S
    Whether or not unregistered EPs issued to agricultural lessees which appear to be
    irregular on their face can defeat the landowner's rights to agricultural leasehold
    rentals.

    RULING
    NO. Agrarian dispute as defined in Section 3(d) of Republic Act (RA) No.
    6657 refers "to any controversy relating to tenurial arrangements, whether
    leasehold, tenancy, stewardship or otherwise, over lands devoted to agriculture,
    including disputes concerning farmworkers associations or representation of
    persons in negotiating, fixing, maintaining, changing or seeking to arrange terms or
    conditions of such tenurial arrangements. It includes any controversy relating to
    compensation of lands acquired under this Act and other terms and conditions of
    transfer of ownership from landowners to farmworkers, tenants and other agrarian
    reform beneficiaries, whether the disputants stand in the proximate relation of farm
    operator and beneficiary, landowner and tenant, or lessor and lessee."

    Section 3, Rule II of the 2003 DARAB Rules of Procedure:

    SECTION 3. Agrarian Law Implementation Cases. — The Adjudicator or the Board


    shall have no jurisdiction over matters involving the administrative implementation
    of RA No. 6657, otherwise known as the Comprehensive Agrarian Reform Law
    (CARL) of 1988 and other agrarian laws as enunciated by pertinent rules and
    administrative orders, which shall be under the exclusive prerogative of and
    cognizable by the Office of the Secretary of the DAR in accordance with his issuances,
    to wit:

    3.1 Classification and identification of landholdings for coverage under


    the agrarian reform program and the initial issuance of CLOAs and EPs,
    including protests or oppositions thereto and petitions for lifting of such coverage;

    2
    AGRARIAN LAW &
    SOCIAL LEGISLATION

    It is undisputed that petitioner and respondents have an established tenancy


    relationship, such that the complaint for collection of back rentals and ejectment
    is classified as an agrarian dispute and under the jurisdiction of the PARAD and
    thereafter by the DARAB. However, in view of the conflicting claims where petitioner
    asserted ownership over the lot and respondents emphasized that the lot is subject
    to OLT coverage, there is a need to ascertain if the lot is under the agrarian reform
    program. Since the classification and identification of landholdings for
    coverage under the agrarian reform program are Agrarian Law
    Implementation cases, the DAR Secretary should first resolve this issue.

    Therefore, the PARAD of Cabanatuan City had no authority to render a decision


    declaring the lot under OLT coverage. It is therefore essential that the DAR Secretary
    should first resolve the issue on the lot's inclusion or exclusion from OLT coverage
    before a final determination of this case can be had.

    You might also like