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)
Expanded Legal Reasoning Model

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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