Facts:

The case involves the Land Bank of the Philippines (Petitioner) and Federico Suntay, represented by his assignee, Josefina Lubrica (Respondent). The events leading to the case began in 1972 when the Department of Agrarian Reform (DAR) expropriated 948.1911 hectares of Suntay's land in Sta. Lucia, Sablayan, Occidental Mindoro, under Presidential Decree No. 27. The expropriated land was valued at P4,497.50 per hectare, totaling P4,251,141.68. Unsatisfied with this valuation, Suntay filed a petition for determination of just compensation with the Regional Agrarian Reform Adjudicator (RARAD), which was assigned to RARAD Conchita MiAas. On January 24, 2001, RARAD MiAas ruled that the just compensation for the expropriated land was P157,541,951.30. Land Bank sought reconsideration, which was denied, prompting them to file a petition for judicial determination of just compensation in the Regional Trial Court (RTC) of San Jose, Occidental Mindoro, on April 20, 2001. The RTC dismi...

Facts:

Background of the Case

• Respondent Federico Suntay owned a 3,682.0285-hectare land in Sta. Lucia, Sablayan, Occidental Mindoro.
• In 1972, the Department of Agrarian Reform (DAR) expropriated 948.1911 hectares of Suntay’s land under Presidential Decree No. 27.
• The Land Bank of the Philippines (Land Bank) and DAR initially valued the expropriated land at P4,497.50/hectare, totaling P4,251,141.68.

Dispute Over Valuation

• Suntay rejected the valuation and filed a petition for determination of just compensation with the Regional Agrarian Reform Adjudicator (RARAD) of Region IV, DARAB, docketed as DARAB Case No. V-0405-0001-00.
• On January 24, 2001, RARAD Conchita Miñas fixed the just compensation at P157,541,951.30.
• Land Bank moved for reconsideration, but RARAD Miñas denied the motion on March 14, 2001.

Judicial Proceedings

• On April 20, 2001, Land Bank filed a petition for judicial determination of just compensation in the Regional Trial Court (RTC) of San Jose, Occidental Mindoro, as a Special Agrarian Court, docketed as Agrarian Case No. R-1241.
• Despite the pending RTC case, RARAD Miñas declared her January 24, 2001 decision final and executory on May 22, 2001, and issued a writ of execution on July 18, 2001.
• Land Bank filed a petition for certiorari with DARAB (DSCA No. 0252) to nullify RARAD Miñas’ decision and related orders.

Court of Appeals (CA) Proceedings

• On September 20, 2001, Josefina Lubrica (Suntay’s assignee) filed a petition for prohibition in the CA (CA-G.R. SP No. 66710) to prevent DARAB from proceeding with DSCA No. 0252.
• The CA granted Lubrica’s petition, ruling that DARAB had no jurisdiction over certiorari petitions.
• Land Bank also filed a petition for certiorari in the CA (CA-G.R. SP No. 70015) challenging the RTC’s dismissal of its petition for judicial determination of just compensation.

Supreme Court (SC) Proceedings

• The SC, in G.R. No. 159145 (DARAB v. Lubrica), ruled that DARAB had no jurisdiction over certiorari petitions.
• In G.R. No. 157903 (Land Bank v. Suntay), the SC held that the RTC erred in dismissing Land Bank’s petition for judicial determination of just compensation, emphasizing that the RTC has original and exclusive jurisdiction over such matters.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction of Special Agrarian Courts: Under Section 57 of CARL, the RTC, acting as a Special Agrarian Court, has original and exclusive jurisdiction over petitions for determination of just compensation. DARAB’s role is limited to preliminary valuation.
2. Finality of Decisions: A petition for judicial determination of just compensation is an original action, not an appeal. Thus, the 15-day reglementary period under DARAB rules does not apply.
3. DARAB’s Limited Jurisdiction: DARAB has no jurisdiction over special civil actions like certiorari, as such authority is not expressly granted by CARL or related laws.
4. Judicial Review: The courts retain the ultimate authority to decide just compensation, ensuring that landowners receive fair and equitable compensation for expropriated properties.

Conclusion:

The Supreme Court directed the RTC to continue proceedings for the determination of just compensation in Agrarian Case No. R-1241. It also nullified the RARAD’s orders and writs of execution, affirming Land Bank’s entitlement to dividends from levied shares. The Court further ordered investigations into the conduct of RARAD Miñas and the DARAB sheriffs involved in the case.