Department of Agrarian Reform Adjudication Board v. Lubrica
REITERATIONFacts
The Antecedents: Federico Suntay filed a petition for fixing and payment of just compensation under Presidential Decree No. 27 against the Department of Agrarian Reform (DAR), the DAR Regional Director for Region IV, and the Land Bank of the Philippines (Land Bank), concerning his landholdings totaling 948.1911 hectares. Suntay had assigned his rights to herein respondent Josefina Lubrica. The DAR and Land Bank valued the property at ₱4,251,141.68, which Suntay deemed unconscionably low. The Regional Agrarian Reform Adjudicator (RARAD) ruled in favor of Suntay, ordering Land Bank to pay ₱157,541,951.30 as just compensation. Land Bank's motion for reconsideration was denied by the RARAD. Procedural History: Land Bank filed a petition for just compensation with the Regional Trial Court (RTC), acting as a special agrarian court, against Suntay, DAR, and RARAD. The RTC dismissed Land Bank's petition for failure to pay docket fees within the reglementary period. While this appeal was pending, the RARAD declared its decision final and executory, noting Land Bank's petition to the special agrarian court was filed beyond the fifteen-day reglementary period. The RARAD denied Land Bank's motion for reconsideration and issued a Writ of Execution. Land Bank then filed a Petition for Certiorari with the DARAB, seeking to nullify the RARAD's issuances. Subsequently, Josefina Lubrica filed a Petition for Prohibition with the Court of Appeals (CA), seeking to enjoin DARAB from proceeding with the certiorari petition, arguing DARAB lacked jurisdiction. The CA granted Lubrica's prayer for a temporary restraining order. Despite this, DARAB issued a Writ of Preliminary Injunction. The CA ruled that DARAB had no jurisdiction to take cognizance of the certiorari petition and issued a Writ of Prohibition, perpetually enjoining DARAB from proceeding with the case. The Petition: The Department of Agrarian Reform Adjudication Board (DARAB), represented by DAR Secretary Roberto M. Pagdanganan, appealed the CA's decision, arguing that the CA erred in ruling that DARAB had no personality to file a comment, that DARAB had no jurisdiction over the certiorari petition, and that the preliminary injunction issued by DARAB was void.
Issue(s)
Whether the DARAB has jurisdiction over a petition for certiorari filed by the Land Bank. Whether the DARAB erred in issuing a writ of preliminary injunction despite a temporary restraining order from the Court of Appeals. Whether the DARAB had the personality to file a comment on the petition for prohibition before the Court of Appeals.
Ruling
The petition is DENIED. The Supreme Court affirms the ruling of the Court of Appeals that the DARAB does not have jurisdiction over Land Bank's petition for certiorari. The dispositive portion of the Court of Appeals' decision, which declared DARAB without jurisdiction and ordered the dismissal of the case, is upheld.
Ratio Decidendi
On the jurisdiction of DARAB over a petition for certiorari: The Supreme Court affirmed the Court of Appeals' ruling that the DARAB does not possess jurisdiction over a petition for certiorari. Jurisdiction, defined as the legal power to hear and determine a cause, must be expressly conferred by law or the Constitution. The authority to issue writs of certiorari, prohibition, and mandamus is an exercise of original jurisdiction that cannot be implied. While the DARAB is vested with quasi-judicial powers and the primary jurisdiction to determine and adjudicate agrarian reform matters under Republic Act No. 6657, this authority is limited to agrarian reform matters and does not extend to extraordinary writs like certiorari. The DARAB's rule-making power does not grant it the authority to self-confer jurisdiction over such matters. The Court emphasized that the quantum of judicial or quasi-judicial powers an administrative agency may exercise is defined in its enabling act, and the DARAB's limited jurisdiction does not include authority over petitions for certiorari in the absence of an express grant. The Court noted that Land Bank received the order denying its motion for reconsideration on March 26, 2001. However, Land Bank filed its petition for just compensation with the special agrarian court only on April 20, 2001, which was beyond the fifteen-day reglementary period prescribed by Rule XIII, Section 11 of the DARAB Rules of Procedure. This failure to file within the reglementary period meant that the RARAD's decision had already attained finality, notwithstanding Land Bank's recourse to the special agrarian court. This procedural lapse was a critical factor in the subsequent proceedings. The Court reiterated that the statutes allowing the DARAB to adopt its own rules of procedure do not grant it unbridled discretion to confer upon itself jurisdiction. Procedure is the means by which jurisdiction is put into action, and rules of procedure are remedial, not substantive. They cover rules on pleadings and practice, but do not expand or diminish the substantive jurisdiction of a tribunal. Therefore, DARAB's adoption of rules did not empower it to hear and decide petitions for certiorari. On whether the DARAB erred in issuing a writ of preliminary injunction despite a temporary restraining order from the Court of Appeals: DARAB argued that its action in issuing the writ of preliminary injunction was an exercise of its residual power of supervision to ensure that the RARAD acted within its delegated authority. However, the Supreme Court clarified that while DARAB has supervisory authority over its delegates like RARADs, this supervision should be exercised within the context of administrative supervision and control. The function of a writ of certiorari is to keep an inferior court within its jurisdiction or to prevent grave abuse of discretion. By taking upon itself the power to correct errors of jurisdiction, DARAB was exercising a power ordinarily lodged with regular courts by virtue of express constitutional or legislative enactments, which it did not possess. On whether the DARAB had the personality to file a comment on the petition for prohibition before the Court of Appeals: While the Court of Appeals held that DARAB should not have filed a comment as a mere formal party, the Supreme Court found DARAB's explanation satisfactory. DARAB argued it had a peculiar interest in the outcome due to its role as an adjunct of the DAR and its adherence to the State's agrarian reform policy. The Court acknowledged that DARAB, composed of senior DAR officials, has an interest that is not purely legal but also a matter of governance, thus it could not be strictly considered a nominal party.
Main Doctrine
The Department of Agrarian Reform Adjudication Board (DARAB), as a quasi-judicial body with limited jurisdiction, cannot exercise jurisdiction over a petition for certiorari absent an express statutory grant of such power. The authority to issue writs of certiorari, prohibition, and mandamus involves the exercise of original jurisdiction which must be expressly conferred by the Constitution or by law, and is never derived by implication.