Case Digest (G.R. No. 221484)
Facts:
Robustum Agricultural Corporation v. Department of Agrarian Reform and Land Bank of the Philippines, G.R. No. 221484, November 19, 2018, Supreme Court Third Division, Peralta, J., writing for the Court.Petitioner Robustum Agricultural Corporation is the registered owner of a 50,000-square meter parcel in Silay City (TCT No. T-15256), formerly part of a 300,000-square meter estate owned by Puyas Agro, Inc. On December 5, 2013, the Department of Agrarian Reform (DAR), through Provincial Agrarian Reform Officer Teresita R. Mabunay, prepared a transmittal letter furnishing petitioner a copy of a notice of coverage (NOC) that identified the mother estate as subject to agrarian reform and informing petitioner that, as a transferee, it would be included as an “alternative land owner and payee.” Petitioner refused to receive that transmittal and the attached NOC.
On June 11, 2014, the DAR issued another NOC that identified the mother estate and the subject land; the NOC was published on June 12, 2014 in the Philippine Star. On August 14 (record reflects 2014), petitioner filed in the Regional Trial Court (RTC), Branch 69, Silay City, a petition for quieting of title and declaratory relief against the DAR and the Land Bank of the Philippines (LBP), challenging the efficacy of the DAR’s June 11, 2014 NOC on two grounds: (1) the DAR resorted immediately to newspaper publication instead of first effecting personal service in violation of DAR Administrative Order No. 07-11, Section 16; and (2) the NOC was not posted on the subject land and on the municipal/barangay bulletin board for seven days as required by Section 19 of DAR AO No. 07-11.
Both respondents answered and raised a common jurisdictional objection: the RTC lacked jurisdiction because questions concerning implementation of the agrarian reform program fall within the DAR’s exclusive original/quasi-judicial jurisdiction under Section 50 of Republic Act No. 6657 (CARL), as amended. On June 11, 2015, the RTC dismissed petition...(Pro-only)
Issues:
- Did the Regional Trial Court have jurisdiction to entertain petitioner’s petition for quieting of title and declaratory relief challenging the DAR’s notice of coverage?
- Does Section 30 of Republic Act No. 9700 operate to deprive the DAR of authority to continue and conclude agrarian reform implementation proceedings (including exercising its quasi‑judicial powers) that ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)