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CIPRIANO CENTENO v. IGNACIA CENTENO

This case has been cited 9 times or more.

2011-01-31
MENDOZA, J.
Under Section 50 of R.A. No. 6657[23] and as held in a string of cases, "the DAR is vested with the primary jurisdiction to determine and adjudicate agrarian reform matters and shall have the exclusive jurisdiction over all matters involving the implementation of the agrarian reform program."[24] The DARAB was created, thru Executive Order No. 109-A, to assume the powers and functions with respect to the adjudication of agrarian reform cases.  Hence, all matters involving the implementation of agrarian reform are within the DAR's primary, exclusive and original jurisdiction. At the first instance, only the DARAB, as the DAR's quasi-judicial body, can determine and adjudicate all agrarian disputes, cases, controversies, and matters or incidents involving the implementation of the CARP.[25] An agrarian dispute refers to any controversy relating to tenurial arrangements, whether leasehold, tenancy, stewardship, or otherwise, over lands devoted to agriculture, including disputes concerning farmworkers' associations or representation of persons in negotiating, fixing, maintaining, changing, or seeking to arrange terms or conditions of such tenurial arrangements. It includes any controversy relating to compensation of lands acquired under this Act and other terms and conditions of transfer of ownership from landowner to farmworkers, tenants, and other agrarian reform beneficiaries, whether the disputants stand in the proximate relation of farm operator and beneficiary, landowner and tenant, or lessor and lessee.[26]
2008-02-27
PUNO, CJ.
Under Section 50 of R.A. No. 6657, "all matters involving the implementation of agrarian reform" are within the DAR's primary, exclusive and original jurisdiction, and at the first instance, only the DARAB as the DAR's quasi-judicial body, can "determine and adjudicate all agrarian disputes, cases, controversies, and matters or incidents involving the implementation of the Comprehensive Agrarian Reform Program under R.A. No. 6657, E.O. Nos. 229, 228 and 129-A, R.A. No. 3844 as amended by R.A. 6389, P.D. No. 27 and other agrarian laws and their implementing rules and regulations."[22]
2006-11-30
CARPIO MORALES, J.
The DARAB has been created to assume the adjudicative powers and functions of the DAR.[19] Thus, the DARAB has been vested with jurisdiction to try and decide all agrarian disputes, cases, controversies, and matters or incidents involving the implementation of the Comprehensive Agrarian Reform Program (CARP).[20] Its jurisdiction encompasses cases involving the "rights and obligations of persons, whether natural or juridical, engaged in the management, cultivation and use of all agricultural lands" covered by Republic Act No. 6657 and other agrarian laws.[21]
2005-09-30
TINGA, J.
Petitioner is also estopped from questioning the  jurisdiction of the Ombudsman. A perusal of the records  shows that he participated in the proceedings by filing his counter-affidavit with supporting evidence.  Neither did he inform the Ombudsman of the existence of the other administrative complaint  of which he is presumably aware at the time the proceedings in the Ombudsman were on-going.   It was only when the Ombudsman rendered an adverse decision that he disclosed the proceedings before the Quezon City Council and raised the issue of jurisdiction. Thus, it has been held that participation in the administrative proceedings without raising any objection thereto bars the parties from raising any jurisdictional infirmity after an adverse decision is rendered against them.[45]
2005-07-29
TINGA, J.
Anent the first assignment of error, there are divergent jurisprudential doctrines touching on this issue.  On the one hand are the cases of Martinez v. Merced,[20] Marquez v. Secretary of Labor,[21] Ducat v. Court of Appeals,[22] Bayoca v. Nogales,[23] Jimenez v. Patricia,[24] Centeno v. Centeno,[25] and ABS-CBN Supervisors Employee Union Members v. ABS-CBN Broadcasting Corporation,[26] all adhering to the doctrine that a party's active participation in the actual proceedings before a court without jurisdiction will estop him from assailing such lack of jurisdiction. Respondent heavily relies on this doctrinal jurisprudence.
2005-06-30
CHICO-NAZARIO, J.
Thus, taking its bearings from the above provision, Centeno v. Centeno[25] explicitly and compellingly validated the jurisdiction of the DARAB over cases involving issuance of CLOAs, and went on further: . . . under Section 50 of R.A. 6657 (the Comprehensive Agrarian Reform Law of 1988), the DAR is vested with primary jurisdiction to determine and adjudicate agrarian reform matters and shall have the exclusive jurisdiction over all matters involving the implementation of the agrarian reform program.  The rule is that the DARAB has jurisdiction to try and decide any agrarian dispute or any incident involving the implementation of the Comprehensive Agrarian Reform Program.  (Italics supplied)
2005-03-18
CHICO-NAZARIO, J.
. . . f) Cases involving the issuance of Certificate of Land Transfer (CLT), Certificate of landownership Award (CLOA) and Emancipation Patent (EP) and the administrative correction thereof; (Italics added) Thus, taking its bearings from the above provision, Centeno v. Centeno[20] explicitly and compellingly validated the jurisdiction of the DARAB over cases involving  issuance of CLOAs, and went on further: . . . under Section 50 of R.A. 6657 (the Comprehensive Agrarian Reform Law of 1988), the DAR is vested with primary jurisdiction to determine and adjudicate agrarian reform matters and shall have the exclusive jurisdiction over all matters involving the implementation of the agrarian reform program.  The rule is that the DARAB has jurisdiction to try and decide any agrarian dispute or any incident involving the implementation of the Comprehensive Agrarian Reform Program.  (Italics supplied)
2002-03-06
QUISUMBING, J.
As held by this Court in Centeno vs. Centeno,[27] "the DAR is vested with the primary jurisdiction to determine and adjudicate agrarian reform matters and shall have the exclusive jurisdiction over all matters involving the implementation of the agrarian reform program." The DARAB has primary, original and appellate jurisdiction "to determine and adjudicate all agrarian disputes, cases, controversies, and matters or incidents involving the implementation of the Comprehensive Agrarian Reform Program under R.A. 6657, E.O. Nos. 229, 228 and 129-A, R.A. 3844 as amended by R.A. 6389, P.D. No. 27 and other agrarian laws and their implementing rules and regulations."[28]
2002-02-27
QUISUMBING, J.
As held previously, participation by parties in the administrative proceedings without raising any objection thereto bars them from raising any jurisdictional infirmity after an adverse decision is rendered against them.[22] In the case at bar, petitioner raised the issue of lack of jurisdiction for the first time in his amended petition for review[23] before the CA. He did not raise this matter in his Motion to Dismiss[24] filed before the CSC Regional Office.  Notably, in his Counter-Affidavit, he himself invoked the jurisdiction of the Commission by stating that he was "open to further investigation by the CSC to bring light to the matter"[25] and by further praying for "any remedy or judgment which under the premises are just and equitable."[26] It is an undesirable practice of a party participating in the proceedings, submitting his case for decision, and then accepting the judgment only if favorable, but attacking it for lack of jurisdiction, when adverse.[27]