CRC 1447 Inc. vs. Rosalinda Calbatea Et Al
CRC 1447 Inc. vs. Rosalinda Calbatea Et Al
CRC 1447 Inc. vs. Rosalinda Calbatea Et Al
Facts:
• The case involves a property owned by Liberty Hizon Vda. De Luna
and Eufemia Rivera.
• The property was subjected to a Notice of Coverage under the
Comprehensive Agrarian Reform Program (CARP) in 1993.
• Rivera filed a petition for extension in 2004, which was denied by
the Department of Agrarian Reform (DAR).
• CRC 1447, Inc. purchased the property in 2006 and registered it
under its name.
• The DAR issued a Notice of Coverage in 2007, denying Rivera's
extension.
• The petitioner received a Notice of Coverage in 2008, but a
petition to lift it was denied.
• The petitioner filed a Complaint for Recovery of Possession against
respondents, who sought dismissal on the grounds of lack of
jurisdiction.
• The Regional Trial Court ruled in favor of the dismissal, and the
Court of Appeals affirmed the ruling.
• The petitioner appealed to the Supreme Court.
Issue:
Whether the courts correctly dismissed the case for lack
of jurisdiction.
Ruling:
The Supreme Court affirmed the dismissal of the case
for lack of jurisdiction.
Ratio:
Jurisdiction over the nature and subject matter of an
action is determined by the allegations in the
complaint.
In this case, the subject property is an agricultural
land placed under the coverage of the CARP.
The issue of possession or use of the property falls
within the jurisdiction of the DARAB.
The DARAB has primary jurisdiction to determine and
adjudicate agrarian reform matters.
The DARAB has exclusive original jurisdiction over all
matters involving the implementation of agrarian
reform.
Therefore, the Supreme Court ruled that the issue of
the recovery of possession of a property under the
CARP falls within the jurisdiction of the DARAB,
resulting in the dismissal of the case for lack of
jurisdiction.