G.R. No.

147525, February 26, 2007 Notes (baka matanong): While the 1989 DARAB Rules provides that the non-answering
BONIFACIO ESPINOZA v PROVINCIAL ADJUDICATOR respondent (Espinoza) may be allowed to belatedly file his answer, it also provides that the
answer should be filed before the matter is submitted for decision. Here, petitioner submitted
FACTS: his answer after the case was submitted for decision.
The issue in this case stemmed from an agrarian dispute before the PARAD of San
Fernando, Pampanga between petitioner and private respondent Maria V. Quibuloy, co-owner Only errors of jurisdiction may be reviewed by the CA in a petition for certiorari. Where the
and administratrix of three parcels of land. She alleged that petitioner had reneged on his issue or question involved affects the wisdom or legal soundness of the decision not the
obligations as tenant to pay the rent and till the subject landholding. jurisdiction of the court to render said decision the same is beyond the province of a special
civil action for certiorari.[17]
Petitioner moved to dismiss the case for lack of jurisdiction. He cited that Section 1, Rule III
of the 1989 DARAB Rules, provided for a certification before the Barangay Agrarian Reform WHEREFORE, the petition is hereby DENIED. SO ORDERED.
Council (BARC) prior to initiating the case – which attested that the dispute had been
submitted to it for mediation or conciliation without any success of settlement – and that such
was a jurisdictional requirement. He concluded that the provincial adjudicator could not take
cognizance of the agrarian dispute due to the absence of said certification.

Hearings (2) were set on the matter by the provincial adjudicator however petitioner failed to
appear before both hearings. Hence, Quibuloy was allowed to present her evidence ex-parte
and the dispute was ordered submitted for decision.

Before the decision was rendered, petitioner filed his answer assailing Quibuloys personality
to bring suit. His defense was the mere denial of Quibuloy’s allegations unsupported by
evidence.

The provincial adjudicator he decided the case against petitioner. [7]

Petitioner then filed a petition for certiorari with the CA – without appealing to the PARAD
and after the lapse of the reglementary period - which the appellate court dismissed, for well-
settled is the rule that certiorari lies only in cases of errors of jurisdiction and not errors of
judgment.

Issue: Is a certification from BARC an indispensable requirement before the PARAD can
acquire jurisdiction of an agrarian dispute?

Ruling: NO. The 1989 DARAB Rules exempted parties residing in non-
adjoining barangays from presenting the BARC certification.[15] Since it is undisputed
that Quibuloy resided in San Nicolas 1st, Lubao, Pampanga while petitioner stayed in San
Agustin, Lubao, Pampanga, the former was not required to present the BARC certification
before the adjudicator taking cognizance of the agrarian dispute.