Title
Heirs of Zoleta vs. Land Bank of the Philippines
Case
G.R. No. 205128
Decision Date
Aug 9, 2017
Eliza Zoleta’s heirs contested DARAB’s improper issuance of a certiorari resolution, leading the Supreme Court to annul it, citing DARAB’s lack of judicial authority and violation of separation of powers.

Case Digest (G.R. No. 205128)

Facts:

  • Parties
    • Petitioners: Heirs of Eliza Q. Zoleta (Sergio Renato Q. Zoleta a.k.a. Carlos Zoleta; Venancio Q. Zoleta; Milagros Q. Zoleta-Garcia)
    • Respondents: Land Bank of the Philippines (Landbank) and Department of Agrarian Reform Adjudication Board (DARAB)
  • Factual and Procedural Background
    • On September 29, 1996, Eliza Zoleta offered for sale under CARP a 136-hectare parcel in Quezon; Landbank valued 125.4704 ha at ₱3,986,639.57, deposited same with DAR, but Eliza rejected it.
    • The case went from PARAD to RARAD, which on October 3, 2000 fixed just compensation at ₱8,938,757.72. Landbank filed for review in the Special Agrarian Court and Eliza moved for execution; RARAD issued a writ of execution (Jan. 16, 2001) and an alias writ (Feb. 15, 2001).
    • Landbank sought quashal in the Special Agrarian Court but failed to implead DARAB, and the court denied relief.
    • On April 2, 2001, Landbank filed before DARAB a “petition for certiorari” under its 1994 Rules, alleging grave abuse by RARAD. DARAB granted relief on May 12, 2006, annulling the RARAD’s order and alias writ.
    • Petitioners then filed a Rule 65 certiorari action in the Court of Appeals (CA) to annul DARAB’s resolution; the CA denied relief in its July 23, 2012 Decision and January 9, 2013 Resolution.
    • Petitioners elevated the case to the Supreme Court via Rule 45 Petition for Review on Certiorari, contesting DARAB’s power to issue writs of certiorari.

Issues:

  • Jurisdictional Power
    • Whether DARAB, as a quasi-judicial administrative agency, has authority to issue writs of certiorari and annul acts of its delegates.
    • Whether DARAB’s own procedural rules (1994 Rules) can supply jurisdiction to entertain certiorari petitions.
  • Separation of Powers
    • Whether the exercise of certiorari by DARAB violates the exclusive vesting of judicial power in courts under the Constitution.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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