Marken v. Landbank
REITERATIONFacts
The Antecedents: Marken, Incorporated (now Aquasalina Incorporated) owned two parcels of land in Occidental Mindoro, totaling over 500 hectares. These properties were subjected to the Compulsory Acquisition Scheme of the Comprehensive Agrarian Reform Program (CARP) by the Department of Agrarian Reform (DAR). The Land Bank of the Philippines (LBP) determined the value of the properties, and after deposits were made, Marken, Inc. rejected the valuation, leading to a referral to the Department of Agrarian Reform Adjudication Board (DARAB) for summary administrative proceedings to fix just compensation. Procedural History: The DARAB, on September 5, 2011, adopted the LBP's valuation as just compensation, finding that Marken, Inc. failed to provide sufficient evidence to support a higher valuation. Marken, Inc.'s motion for reconsideration was denied by the DARAB on September 13, 2012. Aggrieved, Marken, Inc. filed a Petition for Review under Rule 43 of the Rules of Court before the Court of Appeals (CA). The CA, in its April 24, 2015 Decision, dismissed the petition, affirming the DARAB's ruling and holding that Marken, Inc. had resorted to the wrong mode of appeal, as the case should have been filed with the Special Agrarian Court (SAC). The Petition: Marken, Incorporated filed this Petition for Review on Certiorari under Rule 45 of the Rules of Court, essentially arguing that the CA erred in dismissing its appeal. The petitioner contended that its appeal to the CA was to seek redress for the erroneous disposition by the DAR of placing the subject properties under CARP, and that the just compensation should be based on their classification as fishponds and prawn farms, not agricultural land. The petitioner also argued that the LBP failed to consider the value of improvements. The LBP and DAR/DARAB, in their respective comments, argued that the DARAB decision had become final and executory due to the petitioner's resort to the wrong remedy, and that the issues raised were already passed upon by the CA.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for review, considering the petitioner's assertion that the appeal sought redress for the erroneous disposition by the DAR of placing the subject properties under the CARP. Whether the subject properties are covered by the CARP, considering the petitioner's claim of exemption due to their classification as prawn and fishpond, and the validity of the municipal resolution reclassifying the area as industrial. Whether the determination of just compensation by the DARAB and LBP was proper, considering the petitioner's claim that it should be based on their classification as prawn and fishpond, and the valuation factors under Section 17 of R.A. No. 6657 and DAR Administrative Order (AO) No. 5, series of 1998.
Ruling
The petition is denied. The Court affirmed the decisions of the Court of Appeals and the DARAB, upholding the valuation of the subject properties and their coverage under the CARP. The Court found that Marken, Inc. availed of the wrong remedy by directly appealing to the CA instead of filing an original action with the Special Agrarian Court (SAC) for the determination of just compensation. Furthermore, the Court found no error in the DARAB's conclusion that the subject properties were covered by CARP, as the petitioner failed to present sufficient evidence of their exemption or valid reclassification.
Ratio Decidendi
On the issue of the wrong remedy and jurisdiction: The Court reiterated that under Republic Act (R.A.) No. 6657, specifically Section 57, the Special Agrarian Courts (SACs) have original and exclusive jurisdiction over all petitions for the determination of just compensation to landowners. Section 6 of Rule XIX of the DARAB Rules of Procedure mandates that a party who disagrees with the DARAB's decision must contest it by filing an original action with the SAC within fifteen (15) days from receipt of the decision. The petitioner's direct appeal to the Court of Appeals (CA) under Rule 43 of the Rules of Court was therefore the wrong mode of appeal. The failure to file the action with the SAC rendered the DARAB decision final and executory. The Court emphasized that jurisdiction is conferred by law, and the nature of the action is determined by the material averments and the relief sought. On the issue of CARP coverage and land classification: The Court found that the petitioner failed to sufficiently prove that the subject properties were exempt from CARP coverage. While the petitioner presented evidence of previous use as fishponds and prawn farms and a municipal resolution reclassifying the area as industrial, these were deemed insufficient. The Court noted that at the time of the DAR's evaluation in 1998, the properties were classified as idle lands, and evidence of their prior use as fishponds or prawn farms was from ten years prior and did not reflect their actual use at the time of coverage. Furthermore, the reclassification to industrial use was based on a mere resolution, which is insufficient; an ordinance passed after public hearings is required by the Local Government Code (LGC) for such reclassification. Therefore, the properties remained covered by CARP. On the issue of just compensation: The Court found no reversible error in the DARAB's determination of just compensation. The LBP followed the prescribed valuation factors under Section 17 of R.A. No. 6657 and DAR Administrative Order (AO) No. 5, series of 1998, which was the applicable regulation at the time. The DARAB noted that the petitioner failed to provide clear and convincing evidence to overcome the presumption of regularity of the LBP's actions and to support its own claimed valuation. The Court also clarified that while improvements were to be included in the compensation package, the petitioner did not submit sufficient data to justify a higher valuation based on its claimed use as fishponds or prawn farms, especially since the properties were found to be idle lands at the time of coverage. The Court reiterated that it generally defers to the factual findings of administrative agencies like the DAR, which possess specialized knowledge.
Main Doctrine
A landowner who disagrees with the DARAB's decision on just compensation must file an original action with the Special Agrarian Court (SAC) within fifteen (15) days from receipt of the decision; failure to do so renders the DARAB decision final and executory. Furthermore, the reclassification of agricultural lands to industrial use requires an ordinance, not merely a resolution, to be valid.