Facts:

The case involves the Republic of the Philippines, represented by the Department of Agrarian Reform (DAR) and the Land Bank of the Philippines (LBP) as petitioners, against the Court of Appeals and Acil Corporation as respondents. The events leading to this case began when Acil Corporation owned several hectares of land located in Linoan, Montevista, Davao del Norte. The government, under the Comprehensive Agrarian Reform Law (R.A. No. 6657), took possession of these lands, leading to the cancellation of Acil Corporation's certificates of title and the issuance of new titles to farmer-beneficiaries. The LBP initially valued the riceland at P19,312.24 per hectare and the brushland at P4,267.68 per hectare, totaling P439,105.39. However, Acil Corporation had previously filed a Statement of Agricultural Landholdings ("LISTASAKA") with the DAR, indicating a lower "Fair Value Acceptable to Landowner," which led the LBP to reassess the valuation at P15,311.7...

Facts:

1. Ownership and Acquisition of Land:

   • Private respondent Acil Corporation owned several hectares of land in Linoan, Montevista, Davao del Norte.
   • The government acquired the land under the Comprehensive Agrarian Reform Law (R.A. No. 6657).
   • Acil Corporation's certificates of title were canceled, and new titles were issued to farmer-beneficiaries.

2. Valuation of Land:

   • The Land Bank of the Philippines (LBP) valued the land at P19,312.24 per hectare for riceland and P4,267.68 per hectare for brushland, totaling P439,105.39.
   • However, Acil Corporation had earlier filed a Statement of Agricultural Landholdings ("LISTASAKA") with the Department of Agrarian Reform (DAR), stating a lower "Fair Value Acceptable to Landowner" of P15,311.79 per hectare.
   • Based on this, LBP adjusted the valuation to P390,557.84.

3. Dispute Over Valuation:

   • Acil Corporation rejected the government's offer, arguing that nearby lands with similar crops were valued at P24,717.40 per hectare.
   • The matter was brought before the Provincial Agrarian Reform Adjudicator (PARAD), which upheld LBP's valuation on October 8, 1992.

4. Legal Proceedings:

   • On December 12, 1992, Acil Corporation filed a Petition for Just Compensation in the Regional Trial Court (RTC) of Tagum, Davao del Norte, sitting as a Special Agrarian Court.
   • The RTC dismissed the petition, ruling that Acil Corporation should have first appealed to the Department of Agrarian Reform Adjudication Board (DARAB) before filing with the RTC.
   • The RTC also noted that the petition was filed beyond the 15-day period required by DARAB rules.

5. Appeal to the Court of Appeals:

   • Acil Corporation filed a petition for certiorari with the Court of Appeals, arguing that the RTC had exclusive and original jurisdiction over just compensation cases under R.A. No. 6657.
   • The Court of Appeals ruled in favor of Acil Corporation, setting aside the RTC's dismissal and remanding the case for further proceedings.

6. Supreme Court Petition:

   • The government, represented by DAR, filed a petition for review on certiorari with the Supreme Court, arguing that landowners must first appeal to DARAB before resorting to the RTC.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Jurisdiction of Special Agrarian Courts:

   • Section 57 of R.A. No. 6657 grants Special Agrarian Courts (RTCs) original and exclusive jurisdiction over petitions for just compensation.
   • This jurisdiction is distinct from the quasi-judicial powers of the DAR under Section 50 of R.A. No. 6657.

2. Administrative vs. Judicial Functions:

   • The determination of just compensation is a judicial function that cannot be vested in administrative agencies like DAR.
   • The DAR's role is limited to preliminary valuation, while the RTC has the ultimate authority to decide just compensation.

3. DARAB Rules of Procedure:

   • The DARAB's rules cannot override the statutory jurisdiction of the RTC.
   • The New Rules of Procedure of DARAB (adopted May 30, 1994) explicitly allow landowners to bring just compensation cases directly to the RTC, bypassing DARAB.

4. Harmonization of Provisions:

   • Section 50 (quasi-judicial powers of DAR) and Section 57 (jurisdiction of Special Agrarian Courts) must be read in harmony.
   • Cases involving just compensation and criminal offenses under R.A. No. 6657 are exceptions to the DAR's jurisdiction.

5. Procedural Flow for Just Compensation:

   • The Land Bank of the Philippines (LBP) conducts the initial valuation.
   • If the landowner rejects the offer, a summary administrative proceeding is held, and the adjudicator (PARAD, RARAD, or DARAB) fixes the price.
   • If the landowner disagrees, they may file a petition with the RTC, which has the final authority to determine just compensation.

Conclusion:

The Supreme Court ruled that the RTC, as a Special Agrarian Court, has original and exclusive jurisdiction over just compensation cases. Landowners are not required to exhaust administrative remedies with DARAB before filing with the RTC. The decision of the Court of Appeals was affirmed, and the case was remanded to the RTC for further proceedings.