Tanenglian vs. Lorenzo

The Department of Agrarian Reform Adjudication Board (DARAB) lacks jurisdiction over a petition for redemption and declaration of ancestral land where no tenancy relationship exists between the parties, and a Regional Adjudicator acts without jurisdiction by declaring lands as ancestral—a function belonging to the NCIP—and by nullifying Torrens titles in a collateral attack.

Two parcels of land in Baguio City, covered by Transfer Certificates of Title (TCT) in the name of petitioner Mariano Tanenglian, were claimed by respondents—members of indigenous cultural communities—as their ancestral land. Respondents filed a petition for redemption under Section 12 of Republic Act No. 3844 and declaration of ancestral land under Section 9 of Republic Act No. 6657 before the DARAB. The Regional Adjudicator declared the properties ancestral lands, directed the DAR to acquire and distribute them, and ordered the cancellation of the petitioner’s titles, despite expressly finding that no tenancy relationship existed between the parties.

• Subject Properties: Two adjacent parcels of land along Sto. Tomas Baguio Road, totaling 29,742 square meters, registered under TCT Nos. T-29281 and T-29282 in the name of petitioner Mariano Tanenglian.
• DARAB Petition: Respondents, claiming to be members of the Kankanais and Ibalois indigenous communities, filed a petition for redemption under RA 3844 and declaration of ancestral land under RA 6657 before the DARAB.
• Regional Adjudicator’s Finding on Tenancy: The Regional Adjudicator explicitly found that respondents failed to prove any tenancy relationship with the petitioner, precluding application of the right of redemption and disturbance compensation under RA 3844.
• Regional Adjudicator’s Disposition: Notwithstanding the absence of tenancy, the adjudicator applied RA 6657, Sec. 9, declared the properties ancestral lands, ordered the DAR to acquire and distribute them to respondents via CLOAs, and directed the cancellation of the petitioner’s TCTs.
• Procedural Lapse: Petitioner’s appeal fee was postmarked one day late, prompting the Regional Adjudicator to deny the notice of appeal. The DARAB affirmed this denial.
• Prior Adjudication: Petitioner’s titles originated from a judicial reopening of a civil reservation case and had been affirmed with finality in a prior suit for quieting of title (G.R. No. 118515), where several of the respondents were bound as parties.

• Wrong Remedy: Petitioner argued that the Court of Appeals erred in dismissing his Rule 65 petition on the ground that Rule 43 was the proper remedy, asserting that exceptions to the rule warrant a relaxation of procedural technicalities.
• Jurisdiction over Ancestral Lands: Petitioner maintained that the Regional Adjudicator lacked authority to declare the subject properties as ancestral lands, as such delineation and recognition fall under the exclusive mandate of the National Commission on Indigenous Peoples (NCIP) under RA 8371.
• Jurisdiction over Title Nullification: Petitioner argued that the Regional Adjudicator acted without jurisdiction in declaring his TCTs null and void, constituting a prohibited collateral attack on a Torrens title.

• Right of Redemption and Ancestral Land Claim: Respondents insisted they were occupying their ancestral lands, seeking protection under RA 6657 and redemption under RA 3844.
• Procedural Default: Respondents contended that the petitioner lost the right to appeal due to the late payment of the appeal fee, warranting the dismissal of the appeal and the execution of the DARAB decision.

• Procedural Remedy: Whether the Court of Appeals correctly dismissed the Rule 65 petition on the ground that Rule 43 is the exclusive remedy for appeals from quasi-judicial agencies.
• DARAB Jurisdiction (Tenancy): Whether the DARAB has jurisdiction over the petition absent a tenancy relationship between the parties.
• DARAB Jurisdiction (Ancestral Lands): Whether the Regional Adjudicator had the authority to declare the subject properties as ancestral lands.
• Collateral Attack on Title: Whether the Regional Adjudicator acted without jurisdiction in ordering the cancellation and nullification of the petitioner’s Torrens titles.

• Procedural Remedy: The dismissal of the Rule 65 petition was affirmed as correct in principle—Rule 43 is the proper mode of appeal from quasi-judicial agencies, and certiorari cannot substitute for a lost appeal. However, procedural rules were relaxed and the petition given due course because the DARAB decision was void for lack of jurisdiction. A void judgment may be assailed anytime, and exceptions to the rule on erroneous modes of appeal apply when the broader interest of justice so requires or when the lower tribunal acted without jurisdiction.
• DARAB Jurisdiction (Tenancy): The DARAB was devoid of jurisdiction because a tenancy relationship is a jurisdictional prerequisite. All six indispensable elements of tenancy must concur: (1) landowner and tenant; (2) agricultural land; (3) consent; (4) agricultural production purpose; (5) personal cultivation; and (6) harvest sharing. The Regional Adjudicator himself found no tenancy relationship, thereby divesting the DARAB of jurisdiction.
• DARAB Jurisdiction (Ancestral Lands): The Regional Adjudicator overstepped his jurisdiction. Under RA 8371 (IPRA), the delineation and recognition of ancestral domains and lands fall under the exclusive mandate of the National Commission on Indigenous Peoples (NCIP), not the DARAB.
• Collateral Attack on Title: The nullification of the petitioner’s TCTs constituted a collateral attack, which is prohibited under the Torrens system. A Torrens title can only be attacked directly in an action expressly instituted for that purpose. Furthermore, the validity of the petitioner’s titles had been affirmed with finality in a prior quieting of title case binding upon several of the respondents.

• DARAB Jurisdiction — The DARAB's jurisdiction is limited to agrarian disputes. A tenancy relationship cannot be presumed; all six indispensable elements must be established by evidence. Absent a tenancy relationship, the DARAB has no jurisdiction, and the case falls under regular courts.
• Prohibited Collateral Attack on a Torrens Title — A Torrens title cannot be collaterally attacked. An attack made as an incident in another action seeking different relief is collateral and prohibited. The validity of a title can only be challenged in a direct action expressly instituted for that purpose.
• Jurisdiction over Ancestral Lands — Under RA 8371, the identification, delineation, and recognition of ancestral domains and lands are under the primary jurisdiction of the National Commission on Indigenous Peoples (NCIP), not the DARAB.
• Rule 65 vs. Rule 43 — Certiorari under Rule 65 is not a substitute for a lost appeal, which from quasi-judicial agencies must be taken under Rule 43. However, exceptions exist when public welfare, the broader interest of justice, nullity of the writ, or oppressive exercise of judicial authority warrants the relaxation of procedural rules.

• "A tenancy relationship cannot be presumed. There must be evidence to prove the tenancy relations such that all its indispensable elements must be established... All these requisites are necessary to create tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant."
• "It is irrefragable, therefore, that the Regional Adjudicator overstepped the boundaries of his jurisdiction when he made a declaration that the subject properties are ancestral lands and proceeded to award the same to the respondents, when jurisdiction over the delineation and recognition of the same is explicitly conferred on the NCIP."
• "Respondents, thus, cannot pray for the Regional Adjudicator to declare petitioner’s TCTs null and void, for such would constitute a collateral attack on petitioner’s titles which is not allowed under the law. A Torrens title cannot be collaterally attacked."
• "Any decision rendered without jurisdiction is a total nullity and may be struck down anytime... a void judgment is in legal effect no judgment, by which no rights are divested, from which no rights can be obtained, which neither binds nor bonds anyone, and under which all acts performed and all claims flowing therefrom are void."

• Mactan Cebu International Airport Authority v. Mangubat — Followed. Recognized exceptions to the stringent requirement of paying docket fees within the reglementary period, justifying judicial leniency when a party shows willingness to comply and substantial justice requires it.
• Nippon Paint Employees Union-Olalia v. Court of Appeals — Followed. Reiterated that certiorari under Rule 65 is not a substitute for a lost appeal, especially a petition for review under Rule 43.
• Sebastian v. Morales — Followed. Stressed that rules of procedure may be relaxed to relieve a litigant of an injustice not commensurate with their procedural lapse, in the interest of substantial justice.
• Suarez v. Saul — Applied. Enumerated the six indispensable elements of a tenancy relationship, all of which must concur to vest DARAB with jurisdiction.
• Tambunting, Jr. v. Sumabat — Applied. Declared that a void judgment is no judgment at all, from which no rights can be obtained, and may be struck down at any time.

• Section 12, Republic Act No. 3844 (Agricultural Land Reform Code) — Cited as the basis for the respondents' right of redemption, which was deemed inapplicable due to the absence of a tenancy relationship.
• Section 9, Republic Act No. 6657 (Comprehensive Agrarian Reform Law) — Cited by the Regional Adjudicator to declare the land ancestral; however, the provision explicitly mandates that the Torrens System shall be respected.
• Sections 3(a) and (b), 38, 46(a), 52, and 53, Republic Act No. 8371 (Indigenous Peoples' Rights Act) — Applied to strip the DARAB of jurisdiction over ancestral land delineation, conferring such authority exclusively on the National Commission on Indigenous Peoples (NCIP).
• Rule 43, Sections 1, 3, and 4, Rules of Court — Governs appeals from quasi-judicial agencies to the Court of Appeals, establishing the exclusive and proper remedy in lieu of Rule 65.
• DARAB New Rules of Procedure, Rule XIV, Sections 1 and 4 — Govern the perfection of appeals within the DARAB, requiring the filing of a notice of appeal and payment of fees within the reglementary period.

Ma. Alicia Austria-Martinez (Acting Chairperson), Dante O. Tinga, Antonio Eduardo B. Nachura, Ruben T. Reyes.