G.R. No. 154112 - Department of Agrarian Reform vs. Cuenca

Private respondent Roberto J. Cuenca is the registered owner of a parcel of land (Lot No. 816-A, TCT No. 1084) in Brgy. Haguimit, La Carlota City, primarily used for sugar cane cultivation.
The land was placed under the compulsory coverage of the Comprehensive Agrarian Reform Program (CARP) as evidenced by a Notice of Coverage issued on September 21, 1999, by Noe Fortunado, the Municipal Agrarian Reform Officer (MARO) of La Carlota City.
The Notice also indicated that the Land Bank of the Philippines (LBP) was to determine the value of the said land pursuant to Executive Order No. 405 dated June 14, 1990.

On September 29, 1999, Cuenca filed a complaint with the Regional Trial Court (RTC), Branch 63, challenging the Notice of Coverage and alleging the unconstitutionality of EO No. 405.
Cuenca’s complaint argued that:

The implementation of CARP on his landholding exceeded its lawful period, which should have been from June 1988 to June 1992 as provided in the Comprehensive Agrarian Reform Law (CARL).
The inclusion of his property under CARP was void due to non-compliance with the requisite approvals by the Presidential Agrarian Reform Council (PARC) and the Provincial Agrarian Reform Coordinating Committee (PARCOM) under R.A. 7905.
EO No. 405, which purportedly amends, modifies, or repeals provisions of the CARL, is unconstitutional because it was issued after President Corazon Aquino’s law-making powers had ceased with the reorganization of the legislative branch following the 1987 Constitution.
The issuance of the Notice of Coverage violated PD 399 dated February 28, 1974.

On October 5, 1999, MARO Fortunado filed a motion to dismiss the complaint on the grounds that the RTC did not have jurisdiction over the agrarian matter.
The RTC initially issued a Temporary Restraining Order (TRO) on January 12, 2000, halting the implementation of the Notice of Coverage by both MARO and the LBP, and scheduled hearings for a writ of preliminary injunction.
On January 14, 2000, MARO Fortunado filed a Motion for Reconsideration, arguing that the DAR, through his offices, could not be enjoined based on Sections 55 and 68 of R.A. 6657.
On February 16, 2000, the respondent Judge denied the motion to dismiss and issued a Writ of Preliminary Injunction, directing Fortunado and agents of the LBP to cease implementation of the Notice of Coverage.

The DAR intervened by filing a Petition for Review under Rule 45 of the Rules of Court, challenging the RTC’s jurisdiction and the issuance of the writ.
The DAR contended that all controversies arising from the implementation of CARP, being fundamentally agrarian and administrative in nature, fall exclusively within its jurisdiction.
The petition underscored that the law grants the DAR quasi-judicial powers to determine and adjudicate agrarian reform matters, thereby precluding lower courts from issuing injunctions against its actions.

Whether the RTC had jurisdiction over the subject matter considering the case involves agrarian reform issues which are primarily under the exclusive jurisdiction of the DAR.
Whether the nature of the relief sought (annulment of the Notice of Coverage) and the averments of the complaint characterize the dispute as an agrarian matter rather than a purely legal question suitable for judicial review.

Whether the issuance of a writ of preliminary injunction by the RTC violated the explicit prohibitory provisions contained in Sections 55 and 68 of R.A. 6657, which bar lower courts from enjoining administrative acts relating to the implementation of agrarian reform.
Whether the administrative actions taken in the implementation of CARP could be subject to judicial interference given the exclusive quasi-judicial authority granted to the DAR.