Case Digest: Laguna Estates Development Corporation vs Court of Appeals, 335 SCRA 29 ,G.R. No. 119357, July 05, 2000

Laguna Estates Development Corporation vs. Court of Appeals
335 SCRA 29 ,
G.R. No. 119357
July 05, 2000

Facts:
The facts, as found by the Court of Appeals, are as follows:
"On 12 December 1989, some 234.76 hectares of agricultural land situated in Barangay Casile, Cabuyao, Laguna belonging to the Sta. Rosa Realty Development Corporation ("SRRDC", hereafter) was placed by the Department of Agrarian Reform (DAR), through its adjudicatory arm, public respondent DARAB, under the compulsory acquisition scheme of the Comprehensive Agrarian Reform Program (CARP), and subsequently, Certificates of Land Ownership Award (CLOA’s) numbered 00130422, 00130423 and 00130424 with TCT Nos. C-168, C-167 and C-169 334 were issued and award to farmers-beneficiaries, private respondents herein, namely: Rosa T. Amante, et al., Rogelio O. Ayende, et al. and Juan T. Amante, et al., respectively. The compulsory acquisition and distribution of the said 234.76 hectares of land in favor of private respondents were effected by virtue of the Decision dated 19 December 1991 issued by public respondent DARAB in DARAB Case No. JC-R-IV-LAG-0001-00, entitled "Juan T. Amante, et al. vs. Sta. Rosa Realty Development Corp."

"It appears that the aforesaid agricultural lands in Bgy. Casile, Cabuyao, Laguna are isolated and/or separated from the rest of the municipality of Cabuyao, and the only passage way or access road leading to said private respondents’ agricultural lands is the privately owned road network situated within the premises of petitioners CSE and LEDC. Subject to reasonable security regulations, the subject road network is open to the public. But after private respondents were awarded the aforesaid agricultural lands under the CARP Law, petitioners CSE and LEDC prohibited and denied private respondents from utilizing the subject road network, thereby preventing the ingress of support services under the CARP Law, provisions for daily subsistence to, and egress of farm produce from, Bgy. Casile where the farmlands awarded to private respondent are located.On motion by private respondents, DARAB issued an Order on 25 May 1993 directing the unhampered entry and construction of support services coming from the national government, and other provisions for the use and benefit of private respondents in Bgy. Casile, and giving private respondents a right of way over the subject road network owned by petitioners.

Issue:
Whether or not the DARAB has jurisdiction to grant private respondents who are beneficiaries of an agrarian reform program or tenants of adjoining landholdings a right of way over petitioners network of private roads intended for their exclusive use

Held:
​No. The DARAB has no jurisdiction over such issue. For DARAB to have jurisdiction over a case, there must exist a tenancy relationship between the parties. Obviously, the issue of a right of way or easement over private property without tenancy relations is outside the jurisdiction of the DARAB. This is not an agrarian issue. Jurisdiction is vested in a court of general jurisdiction.