Philippine Veterans Bank v. Bases Conversion Development Authority
REITERATIONFacts
The Antecedents: Respondent Bases Conversion Development Authority (BCDA), a government corporation, initiated expropriation proceedings in late 2003 to acquire lands for the Subic-Clark-Tarlac Expressway Project. Ten of these cases were consolidated before Branch 58 of the Regional Trial Court (RTC) of Angeles City. The defendants in these cases were individuals who had acquired the lands as beneficiaries of the comprehensive agrarian reform program, holding Certificates of Land Ownership Awards (CLOAs) and Emancipation Patents (EPs), along with Land Bank of the Philippines, the mortgagee of these lands. Petitioner Philippine Veterans Bank (PVB) intervened, asserting ownership over the properties based on a prior foreclosure of mortgages from 1976 and 1982, alleging that the lands originally belonged to Belmonte Agro-Industrial Development Corp. Procedural History: Petitioner Philippine Veterans Bank (PVB) filed motions to intervene in the expropriation cases before RTC Branch 58, attaching complaints-in-intervention. Branch 58 denied these motions on August 18, 2004, citing that intervention was not allowed in expropriation cases and would cause delay, also noting PVB's pending action for annulment of titles before Branch 62. PVB's motion for reconsideration was denied, leading to a petition for certiorari with the Court of Appeals (CA). On January 26, 2006, the CA dismissed the petition, and a subsequent motion for reconsideration was also denied on June 2, 2006. Meanwhile, Branch 58 proceeded to issue decisions on April 3, 2006, granting the expropriation of the properties, though it did not act on BCDA's prayer to determine ownership. The Petition: PVB filed a petition for review on certiorari with the Supreme Court, arguing that the CA erred in holding that PVB was not entitled to intervene. PVB contended that Section 9, Rule 67 of the Rules of Civil Procedure authorizes courts in expropriation cases to adjudicate conflicting ownership claims. The Supreme Court, however, denied the petition, affirming the CA's decision. The Court ruled that Branch 58 could not pre-empt Branch 62, which had a pending case involving the annulment of titles. Furthermore, the Court noted that jurisdiction over the annulment of CLOAs and EPs lies with the Department of Agrarian Reform Adjudication Board (DARAB), not the RTC. PVB's remedy was to have the expropriation proceeds deposited with the court pending adjudication by the DARAB.
Issue(s)
Whether the Court of Appeals erred in holding that PVB was not entitled to intervene in the expropriation cases before Branch 58 of the Angeles City RTC, considering the pending case in Branch 62 and the jurisdiction of DARAB. Whether the RTC, in an expropriation case, has the authority to adjudicate questions of ownership involving the validity of Certificates of Land Ownership Awards (CLOAs) and Emancipation Patents (EPs), given the primary jurisdiction of the DARAB.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, upholding the dismissal of PVB's petition for certiorari. The Court ruled that Branch 58 correctly denied PVB's intervention.
Ratio Decidendi
On the issue of intervention and the RTC's authority to adjudicate ownership: The Court affirmed that while Section 9, Rule 67 of the Rules of Civil Procedure authorizes courts in expropriation cases to hear and decide conflicting claims regarding ownership, this rule cannot apply to PVB's situation. At the time PVB sought to intervene, its conflict with the farmer beneficiaries regarding the validity of their CLOAs and EPs was already pending before another branch of the RTC (Branch 62), a co-equal branch. Branch 58 had no authority to pre-empt Branch 62's jurisdiction over claims already pending before it. Furthermore, even if PVB subsequently withdrew its actions from Branch 62, the jurisdiction over the annulment of CLOAs and EPs lies with the Department of Agrarian Reform Adjudication Board (DARAB) as vested by Republic Act 6657. On the issue of the RTC's authority and the proper remedy: Branch 58 would still lack the power to adjudicate these ownership issues. The proper remedy for PVB was to secure an order from Branch 58 to have the proceeds of the expropriation deposited with the court pending adjudication of ownership issues by the DARAB, as empowered by Section 9, Rule 67.
Main Doctrine
While courts in expropriation cases may adjudicate conflicting claims of ownership, this power cannot be exercised if the issue of ownership involves the determination of the validity of Certificates of Land Ownership Awards (CLOAs) and Emancipation Patents (EPs), which falls within the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). In such instances, the court may order the expropriation proceeds to be deposited with the court pending adjudication by the DARAB.