Cabral v. Court of Appeals, GR. No. 101974, July 12, 2001

CASE TITLE VICTORIA P. CABRAL VS. COURT OF APPEALS G.R. NO. G.R. No.
101974
PONENTE KAPUNAN, J.: DATE JULY 12, 2001
DOCTRINE The function of the Regional Office concerns the implementation of agrarian reform laws while
that of the DARAB/RARAD/PARAD is the adjudication of agrarian reform cases.
The Court of Appeals has underscored the fact that Section 13 of E.O. No. 129-A authorizes the
DARAB to delegate its powers and functions to the regional office in accordance with the rules and
regulations promulgated by the Board. The authority purportedly provides additional justification
for the Regional Office's jurisdiction over the case. Precisely, however, the DARAB, through its
Revised Rules, has delegated such powers and functions to the RARADs and the PARADs, which,
under Section 3 of the Rules, "are deemed to form part of the DAR Regional Office where they are
stationed."
FACTS Petitioner Victoria Cabral filed a petition before the Barangay Agrarian Reform Council (BARC) for
the cancellation of the Emancipation Patents and Torrens Titles issued in favor of private
respondents. The patents and titles covered portions of the property owned and registered in the
name of petitioner.
Petitioner alleged therein that she was the registered owner of several parcels of land covered by
Original Certificate of Title (OCT) No. 0-1670 of the Registry of Deeds of Bulacan, among which is a
parcel of land described therein as Lot 4 of Plan Psu-164390. The petition further averred that as
early as July 1973, petitioner applied with the Department of Agrarian Reform (DAR) for the
reclassification or conversion of the land for residential, commercial or industrial purposes. The
application for conversion, however, was not acted upon. Instead, on April 25, 1988, Emancipation
Patents, and, thereafter, Transfer Certificates of Title, were issued in favor of private respondents.
Petitioner sought the cancellation of the TCTs on the grounds that: petitioner had a pending
application for conversion and reclassification; the lots covered by the emancipation patents
included areas not actually tilled by private respondents; private respondents had illegally
transferred their rights over the parcels of land covered by the emancipation patents; private
respondents are deemed to have abandoned their rights over the properties; and the subject
property was taken without just compensation.
The Regional Director of DAR dismissed the petition for cancellation of Emancipation of Patents.
1
The petitioner then filed a petition for certiorari in the Court of Appeals questioning the jurisdiction
of the Regional Director.
ISSUE/S Whether or not the jurisdiction over the case pertained to the Department of Agrarian Reform
Agrarian Board not the Regional Director.
RULING/S
The function of the Regional Office concerns the implementation of agrarian reform laws while
that of the DARAB/RARAB/PARAD is the adjudication of agrarian reform cases. The first is
essentially exclusive. It pertains to the enforcement and administration of the laws, carrying them
into practical operation and enforcing their due observance. Thus, the Regional Director is
primarily tasked with implementing laws, policies, rules and regulations within the responsibility of
the agency,” as well as the “agency program in the region.
The second is judicial in nature, involving as it does the determination of rights and obligations of
the parties. To aid the DARAB in the exercise of its function, the Rules grant the Board and
Adjudicators the power to issue subpoenas and injunctions, to cite and punish for contempt, and
to order the execution of its orders and decision, among other powers. The Rules also contain very
specific provisions to ensure the orderly procedure before the DARAB, RARADs, and PARADs.
These provisions govern the commencement of actions, venue and cause of action, the service of
pleadings, the presentation of evidence, motions, appeals and judicial review. Notable are the
provisions intended to prevent multiplicity of suits such as the rules on one suit for one cause of
action, the joinder of causes of action, and the assignment of all incidents of a case to the
Adjudicator to whom the case is assigned. No such powers were granted or provisions adopted
when the purported delegation was made to the Regional Director since.
The Court of Appeals has underscored the fact that Section 13 of E.O. No. 129-A authorizes the
DARAB to delegate its powers and functions to the regional office in accordance with the rules and
regulations promulgated by the Board. The authority purportedly provides additional justification
for the Regional Office's jurisdiction over the case. Precisely, however, the DARAB, through its
Revised Rules, has delegated such powers and functions to the RARADs and the PARADs, which,
under Section 3 of the Rules, "are deemed to form part of the DAR Regional Office where they are
stationed."
It is evident from the foregoing that the DAR, like most administrative agencies, is granted with a
fusion of governmental powers, in this case, a commingling of the quasi-judicial and the executive.
2
The growing complexity of modern life, the multiplication of the subjects of governmental
regulation and the increased difficulty of administering the laws have impelled this constantly
growing tendency toward such delegation.
In delegating these powers, it would hardly seem practical to allow a duplication of functions
between agencies. Duplication results in confusion between the various agencies upon whom
these powers are reposed, and in the public that the agencies are supposed to serve. It divides the
agencies' resources and prevents them from devoting their energy to similarly important tasks. The
intention to avoid this very situation is evident in the various laws' distinct delineation of the
functions of the DARAB/RARAD/PARAD and the DAR Regional Office. Accordingly, the Court must
reject the theory of concurrent jurisdiction between the former and the latter. We hold that the
DAR Regional Office has no jurisdiction over the subject case.

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CASE TITLE VICTORIA P. CABRAL VS. COURT OF APPEALS G.R. NO. G.R. No.

PONENTE KAPUNAN, J.: DATE JULY 12, 2001

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