Springfield Development Corporation, Inc. v. Presiding Judge of the Regional Trial Court of Misamis Oriental, Branch 40, Cagayan de Oro City
REITERATIONFacts
The Antecedents: Petra Capistrano Piit originally owned Lot No. 2291. Springfield Development Corporation, Inc. (Springfield) purchased portions of this lot and developed it into the Mega Heights Subdivision. In 1990, the Department of Agrarian Reform (DAR) issued a Notice of Coverage, placing the property under the Comprehensive Agrarian Reform Law. Despite an opposition from the heirs of Petra Piit, a DARAB Provincial Adjudicator initially ruled that the property was residential and not suitable for agriculture. However, the DAR Regional Director appealed this decision, and subsequently, the DARAB granted a petition for relief from judgment, giving due course to the Notice of Coverage and ordering the acquisition and distribution of the property to farmer-beneficiaries. The DARAB later ordered Springfield and the heirs of Piit to pay P12,340,800.00 for the developed property. Procedural History: Springfield and the heirs of Piit filed a petition with the Regional Trial Court (RTC) of Cagayan de Oro City, Branch 40, seeking to annul the DARAB Decision dated October 5, 1995, and subsequent proceedings, alleging lack of notice and hearing. The RTC dismissed this petition for lack of jurisdiction. Petitioners then filed a special civil action for certiorari, mandamus, and prohibition with the Court of Appeals (CA), arguing that the RTC committed grave abuse of discretion. The CA initially dismissed the petition, ruling that the RTC lacked jurisdiction to annul a DARAB decision as they are co-equal bodies. However, the CA later reconsidered and ordered the elevation of the DARAB records, acknowledging the prayer for prohibition. Despite this, the CA ultimately denied the motion for reconsideration without specifically resolving the prohibition issue. The Petition: The present petition for review on certiorari under Rule 45 of the Rules of Court seeks to overturn the CA's dismissal. Petitioners argue that the CA erred in applying the principle of judicial stability and in divesting the RTC of jurisdiction. They contend that the RTC has general jurisdiction under Batas Pambansa Blg. 129 to annul judgments of quasi-judicial bodies like the DARAB, as no other court was expressly granted such jurisdiction. Petitioners also argue that the CA irregularly dismissed their motion for reconsideration after resolving to entertain their petition for prohibition, thereby departing from the usual course of judicial proceedings. They urge the Supreme Court to take cognizance of their prayer for a writ of prohibition, citing compelling reasons and the need to avoid a miscarriage of justice, as the CA failed to resolve this issue.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction to annul a final judgment of the Department of Agrarian Reform Adjudication Board (DARAB). Whether the Court of Appeals (CA) erred in dismissing the petition for annulment and the subsequent motion for reconsideration, particularly concerning the prayer for a writ of prohibition.
Ruling
The petition is PARTLY GRANTED. The case is REMANDED to the Court of Appeals, which is DIRECTED to resolve petitioners' prayer for the issuance of the writ of prohibition in their Motion for Reconsideration.
Ratio Decidendi
On the jurisdiction of the RTC to annul DARAB judgments: The Court reiterated that the RTC does not have jurisdiction to annul final judgments of the DARAB. This is because the DARAB is a quasi-judicial body that is co-equal with the RTC. The Judiciary Reorganization Act of 1980 (B.P. Blg. 129) vests the Court of Appeals (CA) with exclusive original jurisdiction over actions for annulment of judgments of RTCs, and exclusive appellate jurisdiction over decisions of quasi-judicial agencies. While the RTCs generally have original jurisdiction to issue writs of certiorari, prohibition, and mandamus, this power is typically exercised over inferior courts and quasi-judicial bodies of equal ranking with inferior courts, not those co-equal with the RTC. The DARAB Revised Rules of Procedure and the 1997 Rules of Civil Procedure clearly provide for the appeal of DARAB decisions to the CA, signifying its co-equal status. Therefore, the RTC correctly dismissed the petition for annulment. On the CA's dismissal of the petition and motion for reconsideration, including the writ of prohibition: The Court noted that the CA failed to resolve the petitioners' prayer for a writ of prohibition, which was based on the alleged nullity of the DARAB Decision due to lack of due process. While the CA initially acknowledged the need to address the prohibition issue, it later summarily denied the motion for reconsideration. The Court found that a collateral attack on a void judgment is permissible as an incident of an action to obtain a different relief, based on a court's inherent authority to expunge void acts. However, the Court declined to take primary jurisdiction over the prohibition issue, unlike in the Fortich v. Corona case, due to the absence of compelling circumstances and the need to resolve factual issues regarding the alleged nullity of the DARAB decision. The Court determined that the CA is in a better position to delve into the records and fully adjudicate the case, especially given the conflicting findings between the Provincial Adjudicator and the DARAB regarding the property's nature. Therefore, the case was remanded to the CA for the immediate resolution of the motion for reconsideration concerning the writ of prohibition.
Main Doctrine
The Regional Trial Court (RTC) does not have jurisdiction to annul final judgments of the Department of Agrarian Reform Adjudication Board (DARAB) because the DARAB is a co-equal body with the RTC, and its decisions are beyond the RTC's control. Decisions of the DARAB are appealable to the Court of Appeals.