Jurisdiction over the subject matter

13. Heirs of Simeon Latayan vs Peing Tan, et. Al

G.R. No. 201652/ 776 SCRA 1, December 02, 2015

J. del Castillo

Simeon Latayan, represented by his son, Leonidas, filed an amended complaint seeking the
cancellation of respondent Tan’s CLOA. He alleged that his title to the 2 adjoining lots were
arbitrarily placed under the coverage of CARP sans payment of just compensation. Moreover,
respondents cannot be considered as farmer-beneficiaries because they were never occupants
therein.

Tan, contends that Simeon received the copy of Notice of Coverage. Also Simeon’s
landholdings is extensive so it could be validly be placed under the coverage of CARP.

The Office of the Provincial Adjudicator (PARAD) ruled for Simeon. However, upon appeal, the
Department of Agrarian Reform and Adjudication Board (DARAB) dismissed the case for lack of
jurisdiction and ruled that the case falls within the exclusive jurisdiction of the DAR Secretary. The
CA affirmed.

Issue: Which has subject matter jurisdiction over cancellation of CLOAs in this case?

SC: The DAR Secretary. Petition denied.

While the DARAB may entertain petitions for cancellation of CLOAs, as in this case, its jurisdiction
is, however, confined only to agrarian disputes (Section 1, Rule II of the 1994 DARAB Rules).

The controversy between the parties is not agrarian in nature and merely involves the
administrative implementation of the agrarian reform program which is cognizable by the DAR
Secretary. (Section 1, Rule II of the 1994 DARAB Rules)

The jurisdiction of a court or tribunal over the nature and subject matter of an action is conferred
by law. It must look at the material allegations in the complaint, the issues subject of the
controversy, and the character of the relief prayed for in order to determine whether the nature
and subject matter of the complaint is within its jurisdiction. If the issues between the parties are
intertwined with the resolution of an issue within the exclusive jurisdiction of a court or tribunal,
the dispute must be addressed and resolved by the said court or tribunal.