Helen Lorenzo Cunanan v. Court of Appeals, Teofilo Q. Inocencio, Regional Director, Department of Agrarian Reform Regional Office No. III, and Yolanda Mercado
Who are the parties in this case and what positions do they occupy in the litigation?
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There are two sets of parties to identify: the petitioner and the respondents. The petitioner is Helen Lorenzo Cunanan (referred throughout as Cunanan), the registered owner of a home lot which is the subject of the controversy. The private respondent is Yolanda Mercado (Mercado), who filed a petition for reallocation of the home lot originally awarded to Alejandro Lorenzo, Cunanan's father. The public respondents (official respondents) are the Court of Appeals (CA) and Teofilo Q. Inocencio, Regional Director of the Department of Agrarian Reform Regional Office No. III (DAR-R03), which had adjudicatory authority over Mercado's petition. In short, Cunanan challenges actions of both the DAR-R03 (in issuing orders affecting her title) and the CA (in dismissing her certiorari petition and denying reconsideration).
What property is at the center of the dispute and who held title to it over time?
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The subject property is an 800-square-meter home lot located in Barangay Maligaya, Tarlac City. Initially, the lot was embraced by TCT No. 150056 registered in the name of Alejandro Lorenzo (the father of petitioner Cunanan). At some point the title became registered in the name of Helen Lorenzo (Cunanan) under Transfer Certificate of Title No. 288509. Mercado sought reallocation of that home lot to herself, which initiated the administrative proceedings before the DAR-R03 that ultimately culminated in orders recommending cancellation of TCT No. 288509.
Summarize the procedural steps taken by Mercado before the DAR-R03.
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On January 27, 2009, Mercado filed a petition for reallocation of the home lot before the DAR-R03. After initial proceedings, on April 8, 2010, DAR-R03 issued an Order dismissing Mercado's petition for utter want of merit. Mercado then filed a motion for reconsideration on May 13, 2010. The DAR-R03 reconsidered and, on October 13, 2010, issued an Order setting aside the April 8 dismissal and recommending cancellation of TCT No. 288509. That October 13 Order was later declared final and executory by DAR-R03 in an Order of Finality dated December 1, 2010.
What relief did the DAR-R03 grant in its October 13, 2010 Order and how was it qualified?
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The October 13, 2010 Order set aside the earlier April 8 dismissal and recommended the cancellation of Transfer Certificate of Title No. 288509 issued in the name of Helen Lorenzo (Cunanan), concerning the 800-square-meter lot in Barangay Maligaya. Importantly, the Order contained a qualification: "This Office reserves the right to cancel or revoke this Order in case of misrepresentation, or violation of pertinent existing DAR policies, rules and regulations." Thus, while it recommended cancellation, it explicitly left open the possibility of revocation should misrepresentation or policy violations be shown later.
When did Cunanan first learn of the DAR’s action and what did she do upon learning?
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Sometime in April 2011, Cunanan inquired at the DAR Provincial Office and discovered that an Order of Finality had been issued concerning the October 13, 2010 Order. Upon learning this, she acted promptly: on May 13, 2011, she filed with DAR-R03 a Motion to Quash Order of Finality and Other Orders, asserting she was never informed of the proceedings and thus DAR lacked jurisdiction over her person. On June 13, 2011, she filed a Petition for Relief from Judgment regarding the October 13, 2010 Order, and on June 14, 2011, she filed a Petition for Injunction and Prohibition with Preliminary Injunction before the Court of Appeals.
What were the grounds alleged by Cunanan for seeking to quash the DAR orders and for relief from judgment?
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Cunanan averred that she had not been notified of Mercado's proceedings before DAR nor furnished copies of any pleadings or notices. Because of the lack of service and notice, she argued that DAR never acquired jurisdiction over her person and that the DAR orders resulting in the cancellation of her title deprived her of property without due process, violating her constitutional rights. In her petition for relief from judgment she added that she had a good and substantial defense, never abandoned the property, and, if given notice and an opportunity, would present proof to oppose Mercado's reallocation claim.
What procedural remedy did Cunanan pursue in the CA initially, and what happened to that petition?
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Cunanan filed a Petition for Injunction and Prohibition with Preliminary Injunction before the Court of Appeals, docketed as CA-G.R. SP No. 120083, to enjoin DAR and Mercado from proceeding to cancel her TCT while asserting denial of due process. The CA dismissed that petition by its September 26, 2011 Resolution for failure to comply with its July 8, 2011 requirements (payment of deficient docket fees, MCLE certificate details, and proof of service). That dismissal was made final and executory as reflected in the Entry of Judgment dated January 17, 2012, which recorded that the September 26, 2011 Resolution had become final.
How did the DAR-R03 respond to Cunanan’s motion to quash and petition for relief from judgment after the CA dismissal became final?
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After the CA's dismissal was recorded as final and executive, the DAR-R03 issued an Order dated March 9, 2012 dismissing Cunanan's Motion to Quash Order of Finality and Other Orders, and her Petition for Relief from Judgment, as moot and academic. Cunanan filed a motion for reconsideration, which DAR-R03 denied in an April 9, 2012 Order for lack of merit. These DAR decisions prompted Cunanan to file a petition for certiorari with the Court of Appeals challenging the DAR's March 9 and April 9/19 orders.
What was the nature of the petition Cunanan filed with the Court of Appeals challenging the DAR orders, and on what grounds did she base it?
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Cunanan filed a petition for certiorari with the Court of Appeals seeking to annul the DAR-R03's March 9, 2012 Order (dismissing her motion to quash/order of finality and petition for relief from judgment) and its April 19, 2012 order denying reconsideration. She alleged those DAR orders were issued with grave abuse of discretion amounting to lack or excess of jurisdiction because DAR denied her due process by failing to notify her of the reallocation proceedings and thus rendering the proceedings and orders null and void. She sought annulment on grounds of denial of constitutional due process.
How did the Court of Appeals dispose of Cunanan’s certiorari petition and why?
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The Court of Appeals dismissed the petition for certiorari via its July 31, 2012 Resolution. The CA reasoned that the DAR-R03's orders were rendered in the exercise of quasi-judicial functions and presented mixed questions of fact and law; therefore the appropriate mode of challenge was by appeal in the form of a petition for review under Rule 43 of the Rules of Court. Because the period for filing that petition had lapsed, the CA treated the matter as time-barred and dismissed Cunanan's Rule 65 certiorari petition for being filed out of time. The CA also found the petition for certiorari was filed on July 5, 2012 rather than July 3, 2012, reinforcing the lateness argument. Cunanan's motion for reconsideration of the CA decision was denied on November 26, 2012.
What procedural defenses did the Office of the Solicitor General (OSG) raise on behalf of respondents when the case reached the Supreme Court?
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The OSG argued that a petition for certiorari under Rule 65 was the wrong remedy because certiorari is limited to correcting errors of jurisdiction or grave abuse of discretion and may be used only when there is no other plain, speedy, and adequate remedy in the ordinary course of law. The OSG maintained that because the DAR-R03 decisions were quasi-judicial, the appropriate remedy was an appeal — specifically a petition for review under applicable rules (Rule 45 or Rule 43, depending on context). The OSG further argued that Cunanan failed to establish the requisite grave abuse of discretion by the CA to justify Rule 65 relief, and that the CA's denial was not so gross as to warrant certiorari.
How does the Supreme Court characterize the proper function and requisites of a petition for certiorari under Rule 65 in this decision?
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The Supreme Court reiterates that a petition for certiorari under Rule 65 is proper to correct errors of jurisdiction committed by a lower court or grave abuse of discretion tantamount to lack of jurisdiction. A key essential requisite is that there be no appeal or other plain, speedy, and adequate remedy in the ordinary course of law. The Court emphasizes that certiorari is extraordinary and cannot co-exist with an adequate and specified remedy; when rules prescribe a particular remedy (like an appeal), that remedy should ordinarily be availed of. The petitioner must allege and establish facts showing the inadequacy of other remedies; absent such showing, certiorari may be dismissed.
Did the Supreme Court find that Cunanan had no other adequate remedy? How did it proceed with that question?
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On the face of it, Cunanan did not demonstrate that there was no other plain, speedy, and adequate remedy; she merely alleged grave abuse of discretion. The Supreme Court acknowledged this deficiency but elected to suspend the strict rules in the interest of substantial justice, considering the particular circumstances of the case. The Court reviewed the record and concluded that technical dismissals both at the DAR and CA levels frustrated Cunanan's right to be heard and resulted in deprivation of property without due process. Thus, while the ordinary rule about other remedies was applicable, the Court used its discretion to look beyond procedural defects to address the substantive deprivation of constitutional rights.
What factual deficiencies in the DAR and CA proceedings persuaded the Supreme Court to suspend the rules and grant relief?
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The Supreme Court found that neither the DAR-R03 nor the Court of Appeals substantively addressed the core allegation that Cunanan had not been notified of the proceedings and thus was denied due process. Instead, both bodies resolved the controversy on technical grounds — DAR dismissed her post-judgment remedies as moot after the CA's technical dismissal, and the CA dismissed her injunctive petition and later the certiorari on compliance and timeliness technicalities. Critically, the record did not show that Cunanan was notified or furnished a copy of the order cancelling her title; indeed the Court remarks she "was not even furnished a copy of the order cancelling TCT No. 288509 in her name." This lack of notice and resulting deprivation of property without a hearing prompted the Court to set aside the orders to avoid perpetuating a "travesty of justice."
What constitutional right did the Supreme Court emphasize was violated by the DAR’s proceedings?
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The Supreme Court emphasized the constitutional right to due process. The Court found that Cunanan was deprived of her property without due process of law because she was not notified of Mercado's petition or furnished copies of pleadings or notices, and thus had no opportunity to be heard. The Court found that neither DAR-R03 nor the Court of Appeals properly confronted this central due process claim before disposing of Cunanan's remedies on technical grounds.
How did the Supreme Court evaluate the effect of technical rules when they conflict with substantive rights in this case?
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The Supreme Court reaffirmed the principle that procedural rules are tools to facilitate justice and should not be applied rigidly so as to frustrate substantial rights. The Court stated that if application of the Rules tends to frustrate rather than promote justice, it has the power to suspend the rules or except a particular case from their operation. Citing its own precedents, the Court noted an "emerging trend" to afford litigants the amplest opportunity for proper adjudication free from technical constraints. Given that Cunanan's deprivation of property was at stake and the record reflected a failure to address her due process claim, the Court deemed suspension of the strict procedural requirements appropriate to avoid perpetuating injustice.
What was the Supreme Court’s final disposition of the July 31, 2012 and November 26, 2012 Court of Appeals Resolutions?
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The Supreme Court reversed and set aside the July 31, 2012 and November 26, 2012 Resolutions of the Court of Appeals (which had dismissed Cunanan's petition for certiorari and denied reconsideration). The Court concluded that those CA resolutions should not have been allowed to stand given that they failed to address the due process deprivation and were dispositive in a way that effectively prevented Cunanan from having her day in court on the merits of her constitutional claim.
What orders of the Department of Agrarian Reform did the Supreme Court vacate and set aside?
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The Supreme Court vacated and set aside all the proceedings and orders of the Department of Agrarian Reform, Regional Office No. III, in Dockel No. A-0306-MR-0522-09 (A.R. Case No. LSD-0167-10). This includes the October 13, 2010 Order recommending cancellation of TCT No. 288509 and the Order of Finality of December 1, 2010, as well as the DAR-R03's March 9, 2012 Order dismissing Cunanan's motion to quash and petition for relief from judgment and its April 9, 2012 Order denying reconsideration—all were declared void for having been issued with grave abuse of discretion in violation of due process.
What did the Supreme Court order about the records of the case after vacating the DAR and CA orders?
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After vacating the DAR and CA orders, the Supreme Court ordered that the records of the case be remanded to the Department of Agrarian Reform, Regional Office No. III, for appropriate proceedings. The remand was accompanied by the directive that at all times due process must be accorded to petitioner Cunanan, making clear that the DAR must give her notice and an opportunity to be heard in any further proceedings regarding the subject property.
Did the Supreme Court decide whether Cunanan ultimately wins the title to the property? Explain.
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No. The Supreme Court did not decide the merits of whether Cunanan ultimately possesses a meritorious defense to Mercado's reallocation petition or whether her title should stand. The Court expressly stated that whether or not she has a meritorious defense is immaterial to the remedy it granted. The Court's relief was directed at correcting procedural injustice—vacating orders issued without due process and remanding the case so that Cunanan may be afforded the opportunity to present her position and evidence before the DAR. The October 13, 2010 Order itself even contained a reservation allowing the DAR to cancel or revoke the order in case of misrepresentation or policy violations, demonstrating that further administrative adjudication was contemplated.
On what legal basis did the Supreme Court find grave abuse of discretion that justified setting aside the administrative and appellate resolutions?
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The Supreme Court found grave abuse of discretion in the aggregate of procedural failures: the DAR's adjudication proceeded without affording Cunanan notice and an opportunity to be heard, the CA dismissed her injunctive petition and later the certiorari petition on procedural technicalities rather than addressing the core due process complaint, and the DAR later treated her post-judgment remedies as moot because of the CA's technical dismissal. The Court emphasized that the absence of service and notice meant the DAR never acquired jurisdiction over her person, rendering its decisions void and constituting grave abuse of discretion. The Court further reasoned that allowing such technical dismissals to stand would perpetuate a deprivation of property without due process, which the Court could not allow.
How did the Supreme Court reconcile the usual rule that certiorari is extraordinary with its decision to grant relief in this case?
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While acknowledging that certiorari under Rule 65 is an extraordinary remedy reserved for jurisdictional errors or grave abuse of discretion and is unavailable if there is another speedy and adequate remedy, the Supreme Court exercised its discretion to suspend the strict application of procedural rules in the interest of substantial justice. The Court was persuaded by the record showing that technical grounds were being used to dispose of a claim that alleged denial of constitutional due process and deprivation of property. Given the gravity of the constitutional right at issue and the failure of both DAR and the CA to address the due process claim substantively, the Court found it appropriate to set aside the orders despite the general availability of other remedies.
Which precedents or principles did the Supreme Court cite to justify suspending strict procedural application?
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The Supreme Court cited its well-established principle that rules of procedure are tools to facilitate justice and must not be applied rigidly so as to frustrate substantial justice. The opinion references an "emerging trend" in its rulings to afford litigants the amplest opportunity for proper determination free from technicalities, and it quotes prior decisions stating the power to suspend or disregard rules may be exercised when strict application would result in injustice. Specific cited decisions within the opinion include Nala v. Judge Barroso and Dela Cruz v. Court of Appeals, which underscore the Court's willingness to relax procedural rules to secure substantive justice. The Court used those authorities to justify vacating the orders that had denied Cunanan a hearing.
What practical step did the Supreme Court order to ensure Cunanan’s due process rights were protected going forward?
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The Supreme Court remanded the records to the Department of Agrarian Reform, Regional Office No. III, and explicitly ordered that at all times, due process must be accorded to petitioner Cunanan. Practically, this requires the DAR to afford proper notice and the opportunity to be heard in further proceedings on Mercado's petition for reallocation. The remand effectively reopens the administrative adjudication so the DAR can conduct proceedings consistent with due process and the law.
Explain the role that the DAR’s qualification in its October 13, 2010 Order played in the Supreme Court’s reasoning.
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The October 13, 2010 Order contained a specific qualification reserving the DAR's right to "cancel or revoke this Order in case of misrepresentation, or violation of pertinent existing DAR policies, rules and regulations." The Supreme Court noted this qualification to underscore that the DAR itself contemplated that its recommendation might be revisited upon proper showing. This qualification supported the Court's view that procedural technicalities should not foreclose a substantive adjudication on Redistributive rights and that Cunanan should be allowed to present her defenses; it reinforced the Court's position that justice required allowing the DAR to reassess the matter after proper notice and hearing rather than letting the cancellation become final without affording Cunanan her due process.
How did the Supreme Court view the CA’s reliance on procedural deficiencies in dismissing Cunanan’s petitions?
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The Supreme Court viewed the CA's reliance on procedural deficiencies—noncompliance with requirements like docket fees, MCLE certificate details, proof of service, and timeliness—as a "shortcut" that allowed both the CA and DAR to avoid confronting the central question of whether Cunanan had been denied due process. The Court criticized this approach, reasoning that it amounted to denial of substantive justice. It found that neither the CA nor DAR stated that Cunanan had been notified or furnished copies of pleadings, and therefore, the technical dismissals should not stand when they effectively resulted in deprivation of property without a hearing.
What consequences did the Supreme Court mention could result if it allowed the technical dismissals to stand?
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The Supreme Court warned that allowing the technical dismissals to stand would perpetuate a "travesty of justice" by making permanent what it considered a deprivation of property without due process. The Court found such a result unconscionable and stated that it "cannot rest easy" if the injustice would be made permanent. Hence the Court deemed it necessary to vacate the orders and remand so the administrative process could correctly afford Cunanan due process protections.
Did the Supreme Court demand a finding of misrepresentation or policy violation before remanding the case? Why or why not?
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No, the Supreme Court did not demand a present finding of misrepresentation or policy violation before remanding. The Court's action was procedural and remedial: it vacated the DAR's and CA's orders because they were issued without due process and remanded the case for appropriate proceedings, so that Cunanan could be given an opportunity to present evidence and be heard. The DAR's own qualification in its October 13, 2010 Order suggested that it reserved the right to cancel or revoke its recommendation upon later findings of misrepresentation or policy violations; the Supreme Court left such substantive determinations for the DAR to consider after properly conducted proceedings.
What does the Supreme Court say about the relationship between technicalities and the attainment of justice?
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The Supreme Court underscores that rules of procedure must be viewed as means to achieve justice, not ends in themselves. If applying procedural rules rigidly would frustrate justice, it is within the Court's authority to suspend or disregard such rules. The Court asserts that technicalities must take a backseat to substantive rights when strict application would impede the fair resolution of a case. This philosophy guided the Court's decision to set aside the DAR and CA orders that disposed of Cunanan's remedies on procedural grounds without addressing the due process issue.
What standard did the Supreme Court apply in deciding whether the CA acted with grave abuse of discretion?
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The Supreme Court applied a contextual standard: it examined whether the CA's actions amounted to a denial of substantive justice by disposing of the petition on procedural grounds while ignoring the core due process complaint. The Court looked to whether the CA's dismissal was so patent and gross as to constitute grave abuse of discretion tantamount to lack of jurisdiction—particularly given the interest at stake, i.e., deprivation of property without notice. Finding that neither the DAR nor the CA addressed whether Cunanan had been notified and given an opportunity to be heard, the Supreme Court concluded the CA's resolution amounted to grave abuse of discretion because it permitted a legal process to proceed that effectively deprived Cunanan of property without due process.
After the remand, what procedural protections must the DAR afford Cunanan, as instructed by the Supreme Court?
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On remand, the DAR must afford Cunanan full due process. Practically, this entails providing proper notice of the administrative proceedings, furnishing copies of pleadings and orders, issuing summons as required, and giving her a meaningful opportunity to present evidence and oppose Mercado's petition for reallocation. The Supreme Court's directive to accord due process "at all times" signals that the DAR must ensure every step moving forward complies with procedural safeguards required before depriving any party of property rights.
How does this decision illustrate the interplay between administrative adjudication and judicial review?
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This decision highlights two interrelated principles: (1) administrative bodies like the DAR have quasi-judicial powers to adjudicate claims such as petitions for reallocation, and their decisions can be reviewed by courts; and (2) courts will intervene through judicial review when administrative processes violate fundamental rights such as due process. The CA initially handled Cunanan's challenge, but its procedural dismissals prevented a substantive review. The Supreme Court's action demonstrates that judicial review can correct both administrative and judicial actions when due process is compromised; it vacated administrative and appellate orders and remanded the matter so the administrative forum could again adjudicate the merits under constitutionally required procedures.
Why did the Supreme Court reject the respondents’ argument that the proper remedy was an appeal rather than Rule 65 certiorari?
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The Supreme Court acknowledged the respondents' contention that ordinarily an appeal is the proper avenue to challenge quasi-judicial administrative decisions and that certiorari under Rule 65 is exceptional. However, having reviewed the record and recognizing that technical dismissals had resulted in deprivation of property without due process, the Court exercised its discretionary authority to suspend the strict application of remedial rules to prevent injustice. The Court did not fundamentally reject the principle that an appeal is ordinarily the correct avenue; instead, it found that the particular circumstances—failure to address the due process claim—warranted exceptional relief to correct grave abuse and secure the petitioner's constitutional rights.
What is the practical significance of the Court’s statement that “whether or not she has a meritorious defense is immaterial”?
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The Court's statement underscores that the remedy ordered was about ensuring a fair process, not predetermining the substantive outcome. The practical significance is that even if Cunanan might ultimately lose on the merits, she is constitutionally entitled to be heard before any deprivation of property becomes final. The Court prioritized the procedural guarantee of due process over reaching a substantive decision about title and reallocation. This protects litigants from losing rights through process errors and preserves the legitimacy of administrative adjudication by requiring that it be conducted fairly.
How did the Court characterize the behavior of Cunanan’s counsel and what effect did it have on the procedural posture?
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The Court observed that DAR and the CA might have "correctly cited pertinent technical rules to justify their actions due to the ignorance or negligence of the petitioner's counsel." In other words, the Court acknowledged that counsel's failure to comply with certain procedural requirements contributed to the dismissals. Nonetheless, the Court emphasized that such counsel lapses could not justify denying Cunanan the substantive right to due process and the opportunity to be heard. The petitioner should not be penalized to the point of losing property when the fault lay with counsel's procedural default.
Discuss how the Court balanced respect for procedural rules with protection of constitutional rights in this case.
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The Court recognized the importance of procedural rules, particularly the doctrines limiting certiorari to extraordinary jurisdictional errors and the existence of prescribed remedial channels. But it balanced those doctrines against the fundamental requirement that a party not be deprived of property without due process. The Court reasoned that when strict application of the rules would frustrate substantive justice—here, the denial of a hearing leading to potential loss of title—it has the authority to suspend procedural strictures. Thus, while rules ordinarily guide litigation, the protection of constitutional rights took precedence, prompting the Court to set aside prior orders and remand for proper proceedings.
If you were the trial judge at DAR-R03 after remand, what would be the first procedural steps to take consistent with the Supreme Court’s directive?
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Consistent with the Supreme Court's directive to afford due process, the first steps would be: (1) ensure the docket reflects the remand order and reopen the case in Dockel No. A-0306-MR-0522-09 (A.R. Case No. LSD-0167-10); (2) issue a formal notice of the resumption of proceedings to all parties, especially to petitioner Cunanan, including copies of the remand order and relevant prior DAR pleadings and orders; (3) set a schedule for filing responsive pleadings or submissions by Cunanan and allow reasonable time to prepare; (4) schedule hearings where both parties may present evidence and cross-examine witnesses; and (5) ensure that all procedural notices are documented with proof of service so that there can be no question about whether Cunanan received proper notice. These steps would operationalize the Supreme Court's mandate that due process be observed at all times.
What lessons about appellate strategy and procedural compliance for lawyers can be drawn from this decision?
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This decision illustrates several practical lessons: (1) Strict compliance with procedural requirements is crucial because failures can lead to dismissals that foreclose relief; (2) However, where procedural noncompliance results in denial of an essential right like due process, higher courts may intervene to correct the injustice; (3) Counsel should vigilantly protect clients' constitutional rights—especially notice and opportunity to be heard—and should file timely, properly supported remedies when administrative decisions adversely affect clients' property; and (4) while extraordinary remedies like certiorari are limited, they remain available where procedural outcomes would permit grave and irreparable injury, and courts may relax procedural rules in exceptional circumstances to secure substantive justice.
How might the DAR ensure in future cases that its orders do not run afoul of due process, based on the Supreme Court’s findings?
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To avoid future due process defects, the DAR should: (1) rigorously document service and notice to interested parties, ensuring that summonses, notices of hearing, and copies of pleadings and orders are delivered and proof of delivery retained; (2) maintain transparent records showing attempts at service and responses; (3) when issuing recommendations affecting title, explicitly record the parties' participation and any waivers of notice; (4) be ready to make factual findings on the record if an interested party claims lack of notice; and (5) ensure that orders of finality follow only after confirmed due process has been accorded. These steps would address the Supreme Court's concern that the DAR had not shown Cunanan had been afforded the opportunity to be heard.
Reflect on the broader implications of this decision for administrative agencies exercising quasi-judicial functions.
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The decision serves as a reminder that administrative agencies exercising quasi-judicial powers must adhere to fundamental procedural safeguards, especially notice and opportunity to be heard, because agency determinations can have serious consequences like the loss of property. It also demonstrates that courts will not permit agencies to sidestep constitutional protections through procedural shortcuts. Agencies should therefore ensure robust procedural due process in their internal adjudications, as their decisions are subject to judicial scrutiny and reversal if rights are compromised. The decision reinforces judicial oversight as a check against administrative processes that would otherwise produce unjust results.
Summarize in one paragraph the holding of the Supreme Court in this case.
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The Supreme Court granted the certiorari petition, reversed and set aside the Court of Appeals' July 31, 2012 and November 26, 2012 Resolutions, vacated and set aside all proceedings and orders of the Department of Agrarian Reform, Regional Office No. III in the subject docket for being void for having been issued with grave abuse of discretion and for denying due process, and remanded the records to the DAR-R03 for appropriate proceedings while directing that at all times due process be accorded to petitioner Helen Lorenzo Cunanan.