Zoleta v. Land Bank
REITERATIONFacts
The Antecedents: This case concerns a dispute over the just compensation for a parcel of land voluntarily offered for sale by Eliza Zoleta to the government under the Comprehensive Agrarian Reform Program. Land Bank of the Philippines (Landbank) valued the land at P3,986,639.57, depositing this amount in Eliza's name. However, Eliza rejected this valuation, leading to administrative proceedings. The Regional Agrarian Reform Adjudicator (RARAD) eventually fixed the just compensation at P8,938,757.72. Landbank disagreed with this amount and filed a petition for just compensation before the Special Agrarian Court. Meanwhile, Eliza sought the execution of the RARAD's decision, which resulted in the issuance of an order and an alias writ of execution, followed by garnishment and levy notices. Procedural History: Landbank's attempt to quash the alias writ of execution before the Special Agrarian Court was denied. Subsequently, Landbank filed a petition for certiorari before the Department of Agrarian Reform Adjudication Board (DARAB), alleging grave abuse of discretion by the RARAD. DARAB granted this petition, annulling the order and alias writ of execution. The heirs of Eliza Zoleta (petitioners) then filed a petition for certiorari and prohibition before the Court of Appeals, arguing that DARAB exceeded its authority. The Court of Appeals affirmed DARAB's actions, citing its supervisory authority. This led to the present petition before the Supreme Court. The Petition: The petitioners, the heirs of Eliza Zoleta, filed a Petition for Review on Certiorari under Rule 45 of the Rules of Civil Procedure. They pray for the reversal of the Court of Appeals' decision and resolution, seeking to have DARAB's resolution granting Landbank's petition for certiorari dismissed. The core issue is whether DARAB, as an administrative agency, possesses the power to issue writs of certiorari, which the petitioners argue is an inherent judicial power that administrative agencies cannot arrogate unto themselves, citing the principle of separation of powers and established jurisprudence.
Issue(s)
Whether respondent DARAB has the power to issue writs of certiorari. Whether the Court of Appeals erred in upholding DARAB's resolution granting Landbank's petition for certiorari.
Ruling
The Petition for Review on Certiorari is GRANTED. The assailed July 23, 2012 Decision and January 9, 2013 Resolution of the Court of Appeals are REVERSED and SET ASIDE. Respondent Department of Agrarian Reform Adjudication Board is ordered to dismiss the Petition for Certiorari, docketed as DSCA 0219, filed before it by respondent Land Bank of the Philippines.
Ratio Decidendi
On the issue of DARAB's power to issue writs of certiorari: The Supreme Court held that DARAB possesses no power to issue writs of certiorari. This power is an incident of judicial review, exclusively vested in the courts. Administrative agencies, like DARAB, are not courts of law exercising judicial power. The authority to issue writs of certiorari must be expressly conferred by the Constitution or by law, and cannot be derived by implication or from procedural rules. The Court reiterated its ruling in Department of Agrarian Reform Adjudication Board v. Lubrica, emphasizing that DARAB's supposed certiorari power was provided only by its own rules of procedure, not by law. Furthermore, as an administrative agency belonging to the Executive branch, DARAB is inherently incapable of issuing writs of certiorari, which is a judicial power rooted in the separation of powers. On the Court of Appeals' error in upholding DARAB's resolution: The Supreme Court found that the Court of Appeals erred in justifying DARAB's action by referencing its supervisory authority over RARADs. While DARAB has supervisory authority, this does not grant it the power to exercise certiorari. The Court clarified that such supervisory authority should be exercised within the context of administrative supervision and control. If RARADs act beyond their adjudicatory functions, the aggrieved party may avail of the extraordinary remedy of certiorari before the regular courts. DARAB's attempt to correct perceived errors of jurisdiction through its own rules was deemed an unconstitutional encroachment into the judiciary's domain. The Court concluded that DARAB's self-serving grant of certiorari power in its rules of procedure is itself a grave abuse of discretion amounting to lack or excess of jurisdiction and must be annulled.
Main Doctrine
Administrative agencies, such as the Department of Agrarian Reform Adjudication Board (DARAB), do not possess the power to issue writs of certiorari, as this power is an incident of judicial review exclusively vested in the courts. Such power cannot be derived from procedural rules or implied from supervisory authority.