Case Digest (G.R. No. 205128)
Facts:
Heirs of Eliza Q. Zoleta, namely: Sergio Renato Q. Zoleta, a.k.a. Carlos Zoleta, Venancio Q. Zoleta, and Milagros Q. Zoleta‑Garcia v. Land Bank of the Philippines and Department of Agrarian Reform Adjudication Board, G.R. No. 205128, August 09, 2017, Supreme Court Second Division, Leonen, J., writing for the Court.On September 29, 1996, Eliza Q. Zoleta voluntarily offered for sale to the government, under the Comprehensive Agrarian Reform Program, a 136‑hectare parcel covered by TCT No. T‑87673. Pursuant to Executive Order No. 405, Land Bank of the Philippines (Landbank) valued 125.4704 hectares as covered by the Program and deposited P3,986,639.57 in Eliza’s name; Eliza rejected that valuation. The matter was transmitted to the Regional Agrarian Reform Adjudicator (RARAD) after it was determined to be beyond provincial jurisdiction, and summary administrative proceedings under Rep. Act No. 6657, Section 16(d) ensued.
On October 3, 2000 RARAD Conchita C. Minas fixed just compensation at P8,938,757.72. Landbank filed a petition for just compensation in the Regional Trial Court acting as Special Agrarian Court; Eliza moved for execution before RARAD. RARAD granted execution on January 16, 2001 and issued an alias writ of execution on February 15, 2001; enforcement steps followed but the writs were returned unsatisfied.
Landbank sought relief in the Special Agrarian Court to quash the alias writ, but the court denied relief on March 27, 2001 because DARAB had not been impleaded as a respondent. On April 2, 2001 Landbank filed before the Department of Agrarian Reform Adjudication Board (DARAB) a pleading denominated a “petition for certiorari” under paragraph 2, Section 3, Rule VIII of the 1994 DARAB New Rules of Procedure, alleging grave abuse of discretion by the RARAD in issuing the execution orders.
In a May 12, 2006 Resolution DARAB granted Landbank’s petition and “annulled” the January 16, 2001 Order and the February 15, 2001 alias writ of execution, concluding that the regional adjudicator had erred in treating her decision as final and executory and that DARAB could review such interlocutory orders under its rules. Petitioners (Eliza’s heirs) then filed a Petition for Certiorari and Prohibition under Rule 65 before the Court of Appeals; the Court of Appeals in its July 23, 2012 Decision denied the petition, upholding DARAB’s action as within its supervisory and appellate authority. The Court of Appeals denied reconsideration on January 9, 2013.
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Issues:
- Did DARAB have authority to entertain and grant Landbank’s petition for certiorari and to annul the RARAD’s order and alias writ of execution?
- Did the Court of Appeals err in affirming DARAB’s exercise of certiorari power u...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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