Marasigan v. Provincial Agrarian Reform Officer
REITERATIONFacts
The Antecedents: This case concerns two parcels of land owned by petitioner Benito Marasigan, Jr., totaling 18.0733 hectares, which were subjected to compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP). The Department of Agrarian Reform (DAR) identified portions of these lots for coverage, and the Land Bank of the Philippines (LBP) provided valuations for these portions. Petitioner rejected the DAR's offer to pay the LBP-assessed amounts, leading the DAR to initiate summary administrative proceedings before the Provincial Agrarian Reform Adjudication Board (PARAD) to determine just compensation. Procedural History: The PARAD, through the Provincial Agrarian Reform Officer (PARO), issued decisions on November 17, 2011, affirming the LBP's valuations as just compensation. Petitioner appealed these decisions to the Department of Agrarian Reform Adjudication Board (DARAB), arguing that the subject property should not have been covered by CARP and that the proceedings were flawed due to improper identification of the land. The DARAB dismissed the appeal for lack of jurisdiction, stating that the proper remedy was to file an original action for judicial determination of just compensation with a Special Agrarian Court (SAC). Petitioner then appealed to the Court of Appeals (CA) under Rule 43, reiterating his arguments. The CA denied the petition on November 24, 2014, affirming the DARAB's dismissal and holding that the PARAD's decisions had become final and executory due to petitioner's failure to file an action with the SAC. Petitioner's motion for reconsideration was also denied by the CA on January 6, 2016. The Petition: Petitioner seeks review of the CA's decision and resolution via a Petition for Review on Certiorari under Rule 45 of the Rules of Court. He maintains that the PARO erred in proceeding with the summary administrative proceedings and that the DARAB erred in dismissing his appeal. Petitioner argues that the subject property should not have been included in CARP coverage due to alleged irregularities in the notices and lack of proper identification, and that he was denied the opportunity to participate in field investigations and exercise his retention rights. He further contends that the property is residential and not suitable for agricultural use. The core of his petition is that the lower tribunals erred in not addressing the substantive issues of CARP coverage and land identification, instead dismissing his case on procedural grounds.
Issue(s)
Whether the PARO erred in hearing and ruling on the summary administrative proceeding for the determination of just compensation. Whether the DARAB erred in dismissing petitioner's appeal for lack of jurisdiction. Whether the subject property should have been included in CARP coverage.
Ruling
The Supreme Court denied the petition and affirmed the Decision and Resolution of the Court of Appeals. The Court held that the PARO correctly proceeded with the summary administrative proceeding, and the DARAB correctly dismissed the appeal for lack of jurisdiction. The Court also noted that the issue of whether the subject property should have been included in CARP coverage is a factual matter beyond the scope of a Rule 45 petition.
Ratio Decidendi
On the issue of the PARO's authority to hear and rule on the summary administrative proceeding: The Court reiterated that Section 16(d) of Republic Act No. 6657 (R.A. 6657) mandates the DAR to conduct summary administrative proceedings to determine just compensation if the landowner rejects the offer or fails to reply. The PARO was not at liberty to delay or suspend the decision in these proceedings, as the law requires a decision within 30 days after submission. The principal role of the Board or Adjudicator in these proceedings, as stated in Section 1, Rule XIX of the DARAB Rules, is to determine if the LBP and DAR complied with administrative orders and issuances in their land valuation computations. Therefore, the PARO acted within his powers when he proceeded to hear and decide the summary administrative proceeding. On the issue of the DARAB's dismissal of the appeal for lack of jurisdiction: The Court affirmed the CA's ruling that the DARAB correctly dismissed the appeal for lack of jurisdiction. Section 16(f) of R.A. 6657 provides that any party who disagrees with the PARO's decision on just compensation may bring the matter to the court of proper jurisdiction for final determination. The DARAB Rules, specifically Sections 5 and 6 of Rule XIX, clearly state that decisions of the Board/Adjudicator are no longer appealable to the DARAB. Instead, a party who disagrees must file an original action with the Special Agrarian Court (SAC) within fifteen (15) days from receipt of the decision. Petitioner's failure to file an appeal with the RTC-SAC rendered the PARO's decision final and executory. The DARAB, therefore, correctly recognized that petitioner's appeal was beyond its jurisdiction. On the issue of the subject property's inclusion in CARP coverage: The Court found that the factual issue of whether the subject property should have been included in CARP coverage is beyond the province of a petition for review on certiorari under Rule 45. The Court's function in such petitions is limited to reviewing errors of law, not facts. The determination of whether the property was correctly placed under CARP coverage is a factual matter best left to the lower courts and specialized adjudication bodies. Furthermore, the Court noted that objections to CARP coverage, particularly those concerning exemption or exclusion, fall under Agrarian Law Implementation (ALI) cases and should have been filed with the DAR Regional Director or the Secretary, as provided by Sections 7 and 8, Rule II of the 2003 Rules of Procedure for Agrarian Reform Implementation (ALI) cases.
Main Doctrine
A party aggrieved by a Provincial Agrarian Reform Adjudicator's (PARAD) decision on the preliminary determination of just compensation under the Comprehensive Agrarian Reform Program (CARP) must file an original action for judicial determination of just compensation with the Regional Trial Court (RTC) acting as a Special Agrarian Court (SAC) within fifteen (15) days from receipt of the decision. Failure to do so renders the PARAD's decision final and executory. Issues regarding the propriety of a property's inclusion in CARP coverage fall under Agrarian Law Implementation (ALI) cases and should be filed with the Department of Agrarian Reform (DAR) Regional Director or the Secretary.