51. Fraginal v.
Parañal
516 SCRA 530 (February 23, 2007)
Facts: The heirs of Toribia Belmonte Parañal namely: Felisa Parañal, Abraham Parañal, Pedro Parañal,
Irenea Acabado and Josefa Estoy (Heirs of Toribia Parañal), filed with the Office of the Provincial
Agrarian Reform Adjudicator (PARAD) of the Department of Agrarian Reform Adjudication Board
(DARAB), Camarines Sur, a Complaint for Termination of Tenancy Relationship, Ejectment, and
Collection of Arrear Rentals and Damages,3 docketed as PARAD Case No. R-0503-306-‘98, against
Valentin Fraginal, Tomas P. Fraginal and Angelina Fraginal-Quino (Fraginal, et al.).
Fraginal, et al. filed an Answer questioning the jurisdiction of the PARAD on the ground that
they are not tenants of the Heirs of Toribia Parañal, for the land they are tilling is a 1.1408-hectare
public agricultural land within the exclusive jurisdiction of the Department of Environment and Natural
Resources.4
The PARAD issued a Decision on October 8, 1998 ordering the ejectment of Fraginal, et al.
Two years from issuance of the PARAD Decision, Fraginal, et al. filed with the CA a Petition for
Annulment of Judgment with Prayer for Issuance of Preliminary Injunction and/or Restraining
Order.6 They insisted that the PARAD Decision is void as it was issued without jurisdiction.
Unimpressed, the CA dismissed the Petition. Hence, the herein Petition.
Issue: Whether or not Fraginal, et. al.’s assertion that the PARAD is without jurisdiction is correct.
Ruling: No.
The Supreme Court noted that while the DARAB Rules provide for an appeal to the DARAB
from a decision of the PARAD, Fraginal, et al. did not avail of this remedy. Thus, the Court held that
Fraginal, et. al.’s direct recourse to the CA through a petition for annulment of the PARAD Decision
was therefore ill-fated.