CRC 1447 Inc. vs. Rosalinda Calbatea Et Al

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CRC 1447 INC. VS. ROSALINDA CALBATEA ET AL, G.R. NO.

237102, MARCH 4, 2020

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.

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