Land Bank of the Philippines v. Quilit
REITERATIONFacts
The Antecedents: Respondents Magdalena Quilit and Mauricio Laoyan (now deceased) filed a petition for annulment of sale and redemption of two parcels of agricultural land located in La Trinidad, Benguet. These lands were formerly owned by the Spouses Tolding, mortgaged by them, and subsequently acquired by petitioner Land Bank of the Philippines (LBP) through foreclosure, resulting in the issuance of TCT Nos. T-43270 and T-43271 in LBP's name. Procedural History: The Regional Agrarian Reform Adjudicator (RARAD) ruled that respondents could exercise their right of redemption. LBP's Notice of Appeal was denied by the RARAD for being filed late. Subsequently, the RARAD issued a Writ of Execution. LBP's Motion for Reconsideration of the denial of its appeal and the writ of execution was also denied. A Certificate of Finality and Entry of Judgment was issued. The Petition: LBP filed a Petition for Certiorari with the Department of Agrarian Reform Adjudication Board (DARAB) assailing the RARAD's decision, order, writ of execution, and certificate of finality. The DARAB dismissed LBP's petition, citing Department of Agrarian Reform Adjudication Board v. Lubrica, holding that the DARAB, being a quasi-judicial body, has no jurisdiction to issue writs of certiorari. The Court of Appeals (CA) affirmed the DARAB's decision. LBP then filed a Petition for Review on Certiorari with the Supreme Court.
Issue(s)
Whether the Court of Appeals erred in not resolving the merits of the case, similar to the DARAB, despite LBP showing that the RARAD's decision was not in accordance with law. Whether the rule that the DARAB cannot take cognizance of petitions for certiorari, as laid down in Department of Agrarian Reform Adjudication Board v. Lubrica, should apply to petitions filed with the DARAB in accordance with its rules of procedure then in force and prior to the Lubrica decision, thus warranting dismissal to the prejudice of aggrieved parties who availed of the remedy.
Ruling
The Supreme Court denied the Petition for Review on Certiorari and affirmed the Decision of the Court of Appeals. The Court held that the DARAB erred in dismissing LBP's petition for certiorari for lack of jurisdiction, as the DARAB, being a quasi-judicial body, is inherently incapable of issuing writs of certiorari. The Court reiterated that the power to issue writs of certiorari is an incident of judicial review lodged with the regular courts.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in not resolving the merits of the case: The Court ruled that the CA committed no reversible error in not ruling on the substantive merits of LBP's petition for review. Having found that the remedy of certiorari is not cognizable by the DARAB, it would be futile for the CA to pass upon the other assignments of error of LBP, which essentially involved a review of the RARAD's decision. The Court emphasized that findings of fact of quasi-judicial agencies like the RARAD are generally accorded great weight and finality due to their expertise. Furthermore, the Court declined to examine factual issues, such as the proper reckoning points for filing the Notice of Appeal and whether the lands were agricultural and redeemable, reiterating that it is not a trier of facts and a petition for review on certiorari under Rule 45 covers only questions of law, and LBP failed to show any exception to this rule. The Court also found no merit in LBP's alternative argument that the CA should have ordered the DARAB to give due course to the petition for certiorari by treating it as an appeal, noting that LBP failed to file its motion for reconsideration with the RARAD within the five-day reglementary period as required by the 1994 DARAB New Rules of Procedure. On the issue of whether the Lubrica ruling should apply retroactively: The Court held that the jurisprudential pronouncement in Lubrica remains good law and is controlling. The Court noted that the petitions for certiorari in both Lubrica and Zoleta were filed prior to the promulgation of Lubrica and while the 1994 DARAB New Rules of Procedure were in effect, yet the Court still declared that the DARAB could not acquire jurisdiction. Therefore, there was no reason to carve out an exception for LBP's petition. The Court stressed that RA 6657, the law creating the DARAB, does not confer it authority to take cognizance of petitions for certiorari, and allowing such would sanction an act outside statutory authority and confer judicial power to an administrative agency. The Court reiterated its pronouncements in Lubrica and Zoleta, clarifying that the DARAB's lack of authority over special civil actions for certiorari is not merely due to the absence of a statutory grant. As an administrative agency exercising quasi-judicial but not consummate judicial power, DARAB is inherently incapable of issuing writs of certiorari. This is a matter of separation of powers, as the power to issue writs of certiorari is an incident of judicial review, which is lodged with the regular courts by constitutional fiat. The Court emphasized that mere procedural rules cannot supplant a constitutional or statutory grant of jurisdiction, and that DARAB's self-serving grant of certiorari powers in its rules is a grave abuse of discretion amounting to lack or excess of jurisdiction.
Main Doctrine
The Department of Agrarian Reform Adjudication Board (DARAB), as a quasi-judicial body with limited jurisdiction, is inherently incapable of issuing writs of certiorari, as the power to issue such writs is an incident of judicial review lodged with the regular courts by constitutional fiat, and not with administrative agencies.