CARMELITA M. MERCADO VS. HEIRS OF SERAFIN DE GUZMAN
- G.R. Number: G.R. No. 225427
- Promulgated: 2026-01-26
Doctrine
## Facts of the Case Carmelita M. Mercado (Mercado) filed an action for Annulment of Transfer Certificate of Title Emancipation Patent No. 73307 (TCT EP 73307) against the Heirs of Serafin De Guzman and the Register of Deeds for Nueva Ecija, alleging that an 8,212-square meter portion of a property covered by TCT EP 73307 was erroneously included in their title and that she was in possession of this portion. This action stemmed from an earlier DARAB Case No. 1118'NNE'94, where a Provincial Agrarian Reform Adjudicator (PARAD) decision ordered the generation of an emancipation patent in Mercado's favor and the annotation of the segregation of the 8,212 square meters from TCT EP 73307. Despite the finality of this decision, the Heirs of De Guzman refused to surrender their title. The Heirs of De Guzman claimed that Rogelio De Guzman had lent the contested portion to Mercado, and they later executed a waiver of rights to Mercado on the condition she would assume all obligations related to the property. They further alleged that Mercado failed to pay the obligations, while they fully paid for the property with the Land Bank of the Philippines, including the portion Mercado possessed. The Regional Agrarian Reform Adjudicator (RARAD) dismissed Mercado's complaint, maintained her possession, but stated that the Heirs of De Guzman had options to either sell the portion to Mercado or redeem it. The RARAD also declared the December 20, 1994 PARAD decision null and void for violating the Heirs of De Guzman's right to due process. The Department of Agrarian Reform Adjudication Board (DARAB) eventually set aside both the 1994 PARAD and 2001 RARAD decisions, ruling that both adjudicators encroached on the exclusive jurisdiction of the regional director/DAR secretary concerning administrative matters like reallocation and beneficiary qualification. It reinstated the validity of TCT EP 73307 but ordered the Heirs of De Guzman to pay Mercado the mortgage loan, and Mercado to surrender possession thereafter. The Court of Appeals (CA) later partially granted Mercado's petition, setting aside the DARAB's decision and reinstating the April 5, 2001 RARAD decision, remanding the case for determination of the mortgage debt. Both parties sought reconsideration, which the CA denied. ## Issues 1. Whether the DARAB and its adjudicators (RARAD and PARAD) have jurisdiction over cases involving the cancellation of emancipation patents and the reallocation of agrarian land. 2. Whether the December 20, 1994 PARAD Decision, which ordered the generation of an emancipation patent for Mercado and segregation of land, was valid and had attained finality, precluding its subsequent annulment. ## Decision / Rationale **Issue 1:** The DARAB and its adjudicators do not have jurisdiction over matters strictly involving the administrative implementation of agrarian reform programs, such as the identification and selection of beneficiaries or the reallocation of land. The Court held that the **DARAB's jurisdiction** is confined to **agrarian disputes**, which are controversies relating to tenurial arrangements over lands devoted to agriculture. For a case to be considered an agrarian dispute cognizable by the DARAB, there must exist a tenancy or leasehold relation between the parties, requiring elements such as landowner and tenant/lessee, agricultural land, consent, agricultural production purpose, personal cultivation, and share of harvest. In this case, no tenurial arrangement or joint production agreement existed between Mercado and the Heirs of De Guzman; Rogelio merely lent the land to Mercado. Therefore, the **DARAB had no jurisdiction** over the annulment case (DARAB Case No. 6713'NNE'97) because the cancellation of the emancipation patent was not an agrarian dispute arising from a tenurial arrangement. Furthermore, the **identification and selection of CARP beneficiaries** and the **reallocation of agrarian land** are administrative matters falling under the…