G.R. No. 100091 October 22, 1992
CENTRAL MINDANAO UNIVERSITY REPRESENTED ITS PRESIDENT DR. LEONARDO A. CHUA, petitioner,
vs.
THE DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD, THE COURT OF APPEALS and ALVIN OBRIQUE, REPRESENTING BUKIDNON FREE FARMERS
FACTS:
The petitioner, the CMU, is an agricultural education institution owned and run by the estate located in the town of Musuan, Bukidnon province. It started as a farm school at Marilag, Bukidnon, in early 1910, in response to the public demand for an agricultural school in Mindanao. In the early 1960's, it was converted into a college until it became what is now known as the CMU, but still primarily an agricultural university. On January 16, 1958 the late Carlos P. Garcia, issued Proclamation No. 467, withdrawing from sale or settlement and reserving for the Mindanao Agricultural College, a site which would be the future campus of what is now the CMU. A total land area comprising 3,080 hectares was surveyed and registered and titled in the name of the petitioner.Several tribes belonging to cultural communities, opposed the petition claiming ownership of certain ancestral lands forming part of the tribal reservations. Some of the claims were granted so that what was titled to the present petitioner school was reduced from 3,401 hectares to 3,080 hectares. In 1984, the CMU approved Resolution No. 160, adopting a livelihood program called "Kilusang Sariling Sikap Program" under which the land resources of the University were leased to its faculty and employees. This arrangement was covered by a written contract. The faculty and staff combine themselves to groups of five members each, and the CMU provided technical know-how, practical training and all kinds of assistance, to enable each group to cultivate 4 to 5 hectares of land for the lowland rice projects. Each group pays the CMU a service fee and also a land use participant's fee. It was expressly stipulated that no landlord-tenant relationship existed between the CMU and the faculty and/or employees. This particular program was conceived as a multi-disciplinary applied research extension and productivity program to utilize available land, train people in modern agricultural technology and at the same time give the faculty and staff opportunity within the confines of the CMU reservation to earn additional income to augment their salaries. Among the participants in this program were
Alvin Obrique, Felix Guinanao, Joven Caballero, Nestor Pulao, Danilo Vasquez, Aronio Pelayo and other complainants (respondents).
Obrique was a Physics Instructor at the CMU while the others were employees in the lowland rice project. In 1986, the agri-business project for the production of rice, corn and sugar cane known as Agri-Business Management and Training Project was discontinued due to losses incurred while carrying on the said project. Some CMU personnel, among whom were the complainants, were laid-off when this project was discontinued. The CMU later launched a self-help project called CMU-Income Enhancement Program (CMU-IEP) to develop unutilized land resources, mobilize and promote the spirit of self-reliance, provide socio-economic and technical training in actual field project implementation and augment the income of the faculty and the staff. The one-year contracts expired on June 30, 1988. Some contracts were renewed. Those whose contracts were not renewed were served with notices to vacate. The non-renewal of the contracts, the discontinuance of the rice, corn and sugar can project, the loss of jobs due to termination or separation from the service and the alleged harassment by school authorities, all contributed to, and precipitated the filing of, the complaint.
ISSUES:
1.) Whether or not the DARAB has jurisdiction to hear and decide Case No. 005 for Declaration of Status of Tenants and coverage of land under the CARP.
2.) Whether or not respondent Court of Appeals committed serious errors and grave abuse of discretion amounting to lack of jurisdiction in dismissing the Petition for Review on Certiorari and affirming the decision of DARAB.
RULING:
DARAB JURISDICTION LIMITED ONLY TO MATTERS INVOLVING IMPLEMENTATION OF CARP.
Under Section 4 and Section 10 of R.A. 6657, it is crystal clear that the jurisdiction of the DARAB is limited only to matters involving the implementation of the CARP. More specifically, it is restricted to agrarian cases and controversies involving lands falling within the coverage of the aforementioned program. It does not include those which are actually, directly and exclusively used and found to be necessary for, among such purposes, school sites and campuses for setting up experimental farm stations, research and pilot production centers, etc.Consequently, the DARAB has no power to try, hear and adjudicate the case pending before it involving a portion of the CMU's titled school site, as the portion of the CMU land reservation ordered segregated is actually, directly and exclusively used and found by the school to be necessary for its purposes. SEGREGATING SOME HECTARES OF LAND WITHOUT FINDING THAT COMPLAINANTS ARE TENANTS: GRAVE ABUSE OF DISCRETION.
Where the quasi-judicial body finds that the complainants/petitioners are not entitled to the rights they are demanding, it is an erroneous interpretation of authority for that quasi-judicial body to order private property to be awarded to future beneficiaries. The order segregating 400 hectares of the CMU land was issued on a finding that the complainants are not entitled as beneficiaries, and on an erroneous assumption that the CMU land which is excluded or exempted under the law is subject to the coverage of the CARP. Going beyond what was asked by the complainants who were not entitled to the relief prayed for, constitutes a grave abuse of discretion because it implies such capricious and whimsical exercise of judgment as is equivalent to lack of jurisdiction. NEITHER DARAB OR COURT OF APPEALS HAS RIGHT TO PASS UPON NEEDS OF SCHOOL.
As to the determination of when and what lands are found to be necessary for use by the CMU, the school is in the best position to resolve and answer the question and pass upon the problem of its needs in relation to its avowed objectives for which the land was given to it by the State. Neither the DARAB nor the Court of Appeals has the right to substitute its judgment or discretion on this matter, unless the evidentiary facts are so manifest as to show that the CMU has no real need for the land. The evidence is sufficient to sustain a finding of grave abuse of discretion by respondents Court of Appeals and DAR Adjudication Board. The Court declared the decision of the DARAB and the Court of Appeals as null and void and hereby order that they be set aside, with costs against the private respondents.ARMERS AGRICULTURAL LABORERS ORGANIZATION (BUFFALO), respondents.
CENTRAL MINDANAO UNIVERSITY REPRESENTED ITS PRESIDENT DR. LEONARDO A. CHUA, petitioner,
vs.
THE DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD, THE COURT OF APPEALS and ALVIN OBRIQUE, REPRESENTING BUKIDNON FREE FARMERS
FACTS:
The petitioner, the CMU, is an agricultural education institution owned and run by the estate located in the town of Musuan, Bukidnon province. It started as a farm school at Marilag, Bukidnon, in early 1910, in response to the public demand for an agricultural school in Mindanao. In the early 1960's, it was converted into a college until it became what is now known as the CMU, but still primarily an agricultural university. On January 16, 1958 the late Carlos P. Garcia, issued Proclamation No. 467, withdrawing from sale or settlement and reserving for the Mindanao Agricultural College, a site which would be the future campus of what is now the CMU. A total land area comprising 3,080 hectares was surveyed and registered and titled in the name of the petitioner.Several tribes belonging to cultural communities, opposed the petition claiming ownership of certain ancestral lands forming part of the tribal reservations. Some of the claims were granted so that what was titled to the present petitioner school was reduced from 3,401 hectares to 3,080 hectares. In 1984, the CMU approved Resolution No. 160, adopting a livelihood program called "Kilusang Sariling Sikap Program" under which the land resources of the University were leased to its faculty and employees. This arrangement was covered by a written contract. The faculty and staff combine themselves to groups of five members each, and the CMU provided technical know-how, practical training and all kinds of assistance, to enable each group to cultivate 4 to 5 hectares of land for the lowland rice projects. Each group pays the CMU a service fee and also a land use participant's fee. It was expressly stipulated that no landlord-tenant relationship existed between the CMU and the faculty and/or employees. This particular program was conceived as a multi-disciplinary applied research extension and productivity program to utilize available land, train people in modern agricultural technology and at the same time give the faculty and staff opportunity within the confines of the CMU reservation to earn additional income to augment their salaries. Among the participants in this program were
Alvin Obrique, Felix Guinanao, Joven Caballero, Nestor Pulao, Danilo Vasquez, Aronio Pelayo and other complainants (respondents).
Obrique was a Physics Instructor at the CMU while the others were employees in the lowland rice project. In 1986, the agri-business project for the production of rice, corn and sugar cane known as Agri-Business Management and Training Project was discontinued due to losses incurred while carrying on the said project. Some CMU personnel, among whom were the complainants, were laid-off when this project was discontinued. The CMU later launched a self-help project called CMU-Income Enhancement Program (CMU-IEP) to develop unutilized land resources, mobilize and promote the spirit of self-reliance, provide socio-economic and technical training in actual field project implementation and augment the income of the faculty and the staff. The one-year contracts expired on June 30, 1988. Some contracts were renewed. Those whose contracts were not renewed were served with notices to vacate. The non-renewal of the contracts, the discontinuance of the rice, corn and sugar can project, the loss of jobs due to termination or separation from the service and the alleged harassment by school authorities, all contributed to, and precipitated the filing of, the complaint.
ISSUES:
1.) Whether or not the DARAB has jurisdiction to hear and decide Case No. 005 for Declaration of Status of Tenants and coverage of land under the CARP.
2.) Whether or not respondent Court of Appeals committed serious errors and grave abuse of discretion amounting to lack of jurisdiction in dismissing the Petition for Review on Certiorari and affirming the decision of DARAB.
RULING:
DARAB JURISDICTION LIMITED ONLY TO MATTERS INVOLVING IMPLEMENTATION OF CARP.
Under Section 4 and Section 10 of R.A. 6657, it is crystal clear that the jurisdiction of the DARAB is limited only to matters involving the implementation of the CARP. More specifically, it is restricted to agrarian cases and controversies involving lands falling within the coverage of the aforementioned program. It does not include those which are actually, directly and exclusively used and found to be necessary for, among such purposes, school sites and campuses for setting up experimental farm stations, research and pilot production centers, etc.Consequently, the DARAB has no power to try, hear and adjudicate the case pending before it involving a portion of the CMU's titled school site, as the portion of the CMU land reservation ordered segregated is actually, directly and exclusively used and found by the school to be necessary for its purposes. SEGREGATING SOME HECTARES OF LAND WITHOUT FINDING THAT COMPLAINANTS ARE TENANTS: GRAVE ABUSE OF DISCRETION.
Where the quasi-judicial body finds that the complainants/petitioners are not entitled to the rights they are demanding, it is an erroneous interpretation of authority for that quasi-judicial body to order private property to be awarded to future beneficiaries. The order segregating 400 hectares of the CMU land was issued on a finding that the complainants are not entitled as beneficiaries, and on an erroneous assumption that the CMU land which is excluded or exempted under the law is subject to the coverage of the CARP. Going beyond what was asked by the complainants who were not entitled to the relief prayed for, constitutes a grave abuse of discretion because it implies such capricious and whimsical exercise of judgment as is equivalent to lack of jurisdiction. NEITHER DARAB OR COURT OF APPEALS HAS RIGHT TO PASS UPON NEEDS OF SCHOOL.
As to the determination of when and what lands are found to be necessary for use by the CMU, the school is in the best position to resolve and answer the question and pass upon the problem of its needs in relation to its avowed objectives for which the land was given to it by the State. Neither the DARAB nor the Court of Appeals has the right to substitute its judgment or discretion on this matter, unless the evidentiary facts are so manifest as to show that the CMU has no real need for the land. The evidence is sufficient to sustain a finding of grave abuse of discretion by respondents Court of Appeals and DAR Adjudication Board. The Court declared the decision of the DARAB and the Court of Appeals as null and void and hereby order that they be set aside, with costs against the private respondents.ARMERS AGRICULTURAL LABORERS ORGANIZATION (BUFFALO), respondents.
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