Republic v. Court of Appeals
NEW DOCTRINEFacts
The Antecedents: Private respondent Acil Corporation owned several hectares of land in Linoan, Montevista, Davao del Norte, which the government took pursuant to the Comprehensive Agrarian Reform Law (R.A. No. 6657). The Land Bank of the Philippines (LBP) valued the lands at P19,312.24 per hectare for riceland and P4,267.68 per hectare for brushland, totaling P439,105.39. However, based on a lower 'Fair Value Acceptable to Landowner' stated in the 'LISTASAKA' filed by Acil Corporation, the LBP valued the lands uniformly at P15,311.79 per hectare, fixing the total compensation at P390,557.84. Procedural History: Private respondent rejected the government's offer, citing higher valuations for nearby lands. The matter was brought before the Provincial Agrarian Reform Adjudicator (PARAD), who sustained the LBP's initial valuation. Private respondent then filed a Petition for Just Compensation in the Regional Trial Court (RTC) of Tagum, Davao del Norte, sitting as a Special Agrarian Court, praying for P24,717.40 per hectare. The RTC dismissed the petition, ruling that an appeal to the Department of Agrarian Reform Adjudication Board (DARAB) was necessary before recourse to the RTC, and that the petition was filed beyond the 15-day reglementary period after notice of the PARAD's decision. The RTC denied the motion for reconsideration. Private respondent filed a petition for certiorari with the Court of Appeals (CA), arguing that the RTC had original and exclusive jurisdiction. The CA sustained this contention, set aside the RTC's dismissal order, and remanded the case to the RTC. The Petition: The government, represented by the Department of Agrarian Reform (DAR), filed this petition for review on certiorari with the Supreme Court, questioning whether an appeal to the DARAB is a prerequisite to filing a case for just compensation in the RTC under R.A. No. 6657.
Issue(s)
Whether an appeal from the decision of the provincial agrarian reform adjudicator to the DARAB must first be made before a landowner can resort to the Regional Trial Court (RTC) sitting as a Special Agrarian Court for the determination of just compensation under R.A. No. 6657; and what is the procedure for determination of just compensation. Whether the Regional Trial Court (RTC), sitting as a Special Agrarian Court, has original and exclusive jurisdiction over petitions for the determination of just compensation to landowners under R.A. No. 6657; and what is the nature of the RTC's jurisdiction.
Ruling
The petition is denied, and the decision of the Court of Appeals is affirmed. The Regional Trial Court, sitting as a Special Agrarian Court, has original and exclusive jurisdiction over all petitions for the determination of just compensation to landowners under R.A. No. 6657.
Ratio Decidendi
On the issue of appeal from the DARAB and procedure for determination of just compensation: The Court held that while the DARAB Rules of Procedure previously provided for an appellate jurisdiction of the Board over decisions of agrarian reform adjudicators, rules of procedure cannot confer jurisdiction, as only a statute can do so. Furthermore, the New Rules of Procedure of the DARAB, adopted on May 30, 1994, now explicitly state that decisions on land valuation and preliminary determination of just compensation "shall not be appealable to the Board but shall be brought directly to the Regional Trial Courts designated as Special Agrarian Courts." The Court clarified the procedure under R.A. No. 6657. The LBP is initially responsible for determining the value of lands and the compensation. The DAR makes an offer, and if rejected, a summary administrative proceeding is held where an adjudicator fixes the price. However, if the landowner disagrees with the price fixed by the adjudicator, the landowner may bring the matter directly to the RTC acting as a Special Agrarian Court. On the issue of the RTC's jurisdiction and its nature: The Court held that Section 57 of R.A. No. 6657 explicitly grants Special Agrarian Courts (which are RTCs) original and exclusive jurisdiction over "all petitions for the determination of just compensation to landowners." This provision must be harmonized with Section 50, which vests the DAR with primary jurisdiction over agrarian reform matters; however, cases involving the determination of just compensation and criminal cases under the Act are considered exceptions to the DAR's broad powers. The Court emphasized that the valuation of property in eminent domain is essentially a judicial function, which cannot be vested in administrative agencies. The Court reiterated that the jurisdiction granted to the RTCs as Special Agrarian Courts under Section 57 is "original and exclusive." It would subvert this jurisdiction for the DAR to vest original jurisdiction in compensation cases in administrative officials and then make the RTC an appellate court. Any effort to transfer this jurisdiction to adjudicators and convert the RTC's original jurisdiction into appellate jurisdiction would be contrary to Section 57 and therefore void. The adjudicators' power is limited to a preliminary determination of compensation, with the courts retaining the ultimate power to decide the question.
Main Doctrine
The Regional Trial Courts, designated as Special Agrarian Courts, possess original and exclusive jurisdiction over all petitions for the determination of just compensation to landowners under R.A. No. 6657, and any attempt to vest this jurisdiction in administrative officials or to convert the RTC's original jurisdiction into appellate jurisdiction is void.