Department of Agrarian Reform v. Cuenca
REITERATIONFacts
1. The Antecedents: Private respondent Roberto J. Cuenca is the registered owner of a 81.6117-hectare agricultural land in La Carlota City. On September 21, 1999, the Municipal Agrarian Reform Officer (MARO) issued a Notice of Coverage placing Cuenca's landholding under the compulsory coverage of the Comprehensive Agrarian Reform Program (CARP), with the Land Bank of the Philippines (LBP) tasked to determine the land's value. Cuenca filed a complaint with the Regional Trial Court (RTC) seeking the annulment of this notice and the declaration of unconstitutionality of Executive Order No. 405, Series of 1990, also requesting a preliminary injunction and restraining order. 2. Procedural History: The MARO filed a motion to dismiss the complaint, arguing the RTC lacked jurisdiction. Despite this, the RTC issued a Temporary Restraining Order (TRO) and later denied the motion to dismiss, issuing a Writ of Preliminary Injunction. The Department of Agrarian Reform (DAR), as petitioner, then filed a petition for certiorari with the Court of Appeals (CA), assailing the RTC's injunction order for grave abuse of discretion. The CA denied the DAR's petition, upholding the RTC's jurisdiction and its power to issue the injunction. This led to the DAR filing the present Petition for Review with the Supreme Court. 3. The Petition: The DAR, as petitioner, filed a Petition for Review under Rule 45 of the Rules of Court, assailing the CA's decision. The DAR argues that the CA erred in not recognizing that the issues raised in Cuenca's complaint were agrarian reform matters falling under the exclusive jurisdiction of the DAR, not the trial court. Furthermore, the DAR contends that the CA gravely abused its discretion by sustaining the RTC's writ of injunction, which allegedly violates Sections 55 and 68 of Republic Act No. 6657, prohibiting lower courts from issuing injunctions against the DAR in the implementation of agrarian reform programs.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over a complaint seeking the annulment of a Notice of Coverage under the Comprehensive Agrarian Reform Program (CARP) and the declaration of unconstitutionality of Executive Order No. 405. Whether the RTC committed grave abuse of discretion in issuing a writ of preliminary injunction against the Department of Agrarian Reform (DAR) in the implementation of CARP.
Ruling
The Petition is GRANTED. The challenged Decision and Resolution of the Court of Appeals are REVERSED AND SET ASIDE. The Order of the Regional Trial Court of La Carlota City (Branch 63) dated February 16, 2000, is ANNULLED, and a new one is entered DISMISSING the Complaint in Civil Case 713. The Writ of Preliminary Injunction issued therein is expressly VOIDED.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that all controversies on the implementation of the Comprehensive Agrarian Reform Program (CARP) fall under the jurisdiction of the Department of Agrarian Reform (DAR), even if they raise legal or constitutional questions. The Court emphasized that jurisdiction is conferred by law, and the nature of the action and the issue of jurisdiction are shaped by the material averments of the complaint and the character of the relief sought. The Court traced the evolution of agrarian reform jurisdiction, from the Courts of Agrarian Relations to the RTCs and finally to the DAR, citing various laws and presidential issuances. It concluded that the primary thrust of private respondent's complaint was the annulment of the Notice of Coverage, which is an agrarian reform matter falling under the DAR's quasi-judicial jurisdiction, not the RTC's. The Court reiterated that the issuance of the Notice of Coverage is the first step in acquiring private land under CARP, and its propriety relates to the implementation of CARP, which is under the DAR's authority. Therefore, the RTC was ousted from its authority by the mere expediency of appending an allegedly constitutional or legal dimension to a clearly agrarian issue. The Court also noted that in cases of doubt, jurisprudential trend favors refraining from resolving controversies involving matters that demand the special competence of administrative agencies, even if the questions are also judicial in character. On the issue of preliminary injunction: Having declared that the RTC lacked jurisdiction over the case, the Supreme Court held that the RTC was devoid of authority to issue the assailed Writ of Preliminary Injunction. The Court stressed that such a writ must be stricken down as a nullity, especially in light of the express prohibitory provisions of CARP and relevant Administrative Circulars enjoining trial judges to strictly observe Section 68 of RA 6657. This section explicitly prohibits lower courts from issuing injunctions, restraining orders, prohibitions, or mandates against the DAR in its implementation of the program. Therefore, the issuance of the injunction by the RTC constituted a grave abuse of discretion amounting to lack of jurisdiction.
Main Doctrine
All controversies on the implementation of the Comprehensive Agrarian Reform Program (CARP) fall under the jurisdiction of the Department of Agrarian Reform (DAR), even if they raise legal or constitutional questions. Doubts should be resolved in favor of the DAR due to its special and original authority to hear and adjudicate agrarian matters. Consequently, lower courts are without jurisdiction to issue injunctions against the DAR in the implementation of CARP.