Title
Department of Agrarian Reform Adjudication Board vs. Lubrica
Case
G.R. No. 159145
Decision Date
Apr 29, 2005
Dispute over land valuation under agrarian reform; DARAB lacked jurisdiction for certiorari, RARAD decision final. Supreme Court upheld CA ruling.
certiorari
appropriate court
jurisdiction

Case Summary (G.R. No. 159145)

Factual Background

On August 4, 2000, Federico Suntay filed before the Regional Adjudicator a petition for fixing and payment of just compensation under Presidential Decree No. 27 for landholdings totalling 948.1911 hectares in Sablayan, Occidental Mindoro embraced by Transfer Certificate of Title T-31. The DAR and Land Bank of the Philippines initially valued the property at Four Million Two Hundred Fifty-One Thousand One Hundred Forty-One Pesos and 68/100 (P4,251,141.68), or Four Thousand Four Hundred Ninety-Seven Pesos and 50/100 (P4,497.50) per hectare, a valuation which Suntay contested as unconscionably low.

RARAD Decision on Just Compensation

After summary administrative proceedings, the Regional Adjudicator rendered a Decision on January 24, 2001 ordering Land Bank to pay Federico Suntay One Hundred Fifty-Seven Million Five Hundred Forty-One Thousand Nine Hundred Fifty-One Pesos & 30/100 (P157,541,951.30) as just compensation for the taking of the 948.1911 hectares. Land Bank filed a motion for reconsideration which the RARAD denied in an Order dated March 14, 2001; Land Bank received a copy of that denial on March 26, 2001.

Land Bank's Judicial Recourse and RTC Proceedings

On April 20, 2001, Land Bank filed a petition for just compensation with the Regional Trial Court of San Jose, Occidental Mindoro, docketed as Agrarian Case No. R-1241, seeking a judicial declaration that just compensation was P4,251,141.00. The special agrarian court dismissed the petition on August 6, 2001 for failure to pay docket fees within the reglementary period and subsequently denied Land Bank's motion for reconsideration as pro-forma.

RARAD Finality, Execution and DARAB Petition for Certiorari

Upon motion of Suntay, the RARAD issued an Order on May 22, 2001 declaring its January 24, 2001 Decision final and executory on the ground that Land Bank had filed its petition beyond the fifteen-day reglementary period prescribed by Rule XIII, Section 11 of the DARAB Rules of Procedure. The RARAD denied reconsideration of that order on July 10, 2001 and issued a Writ of Execution on July 18, 2001. Thereafter, Land Bank filed with the DARAB on September 12, 2001 a petition for certiorari with prayer for temporary restraining order and preliminary injunction, docketed as DSCA No. 0252, seeking nullification of the RARAD Decision, the RARAD Order declaring finality, the denial of reconsideration, and the writ of execution.

Court of Appeals Petition for Prohibition and Preliminary Relief

On September 20, 2001, Josefina S. Lubrica, as successor-in-interest to Suntay, filed a Petition for Prohibition in the Court of Appeals, CA-G.R. SP No. 66710, impleading DARAB and Land Bank and seeking to enjoin DARAB from proceeding with DSCA No. 0252 on the ground that Republic Act No. 6657 does not confer upon DAR jurisdiction over special civil actions for certiorari. The Court of Appeals granted a temporary restraining order the same day. Despite that restraint, DARAB issued a Writ of Preliminary Injunction on October 3, 2001 directed at preventing the RARAD from implementing its January 24, 2001 Decision.

Parties' Contentions Before the Court of Appeals

DARAB contended before the Court of Appeals that it acted within its power of supervision over its delegates in issuing the petition for certiorari and in restraining execution of a decision that had not attained finality. Lubrica moved to nullify DARAB's writ and sought contempt. Land Bank argued Lubrica's petition for prohibition was premature, invoked exhaustion of administrative remedies as an alternative route, and questioned Lubrica's standing for not having intervened before the RARAD.

Court of Appeals Ruling

The Court of Appeals, in a decision dated August 22, 2002, held that DARAB had no personality to file a comment in CA-G.R. SP No. 66710 because it was a mere formal party and that DARAB had no constitutional or statutory basis to exercise jurisdiction over Land Bank's petition for certiorari. The appellate court rejected DARAB's reliance on its supervisory power and declared DARAB without jurisdiction to take cognizance of DSCA No. 0252, issuing a Writ of Prohibition perpetually enjoining DARAB from proceeding with DSCA No. 0252 and directing its dismissal.

Issues Presented to the Supreme Court

DARAB sought review before this Court under Rule 45, Rules of Court, assigning error to the Court of Appeals in holding: (1) that DARAB, being a formal party, should not have filed a comment and that Land Bank should have been the co-respondent; (2) that DARAB has no jurisdiction over DSCA No. 0252 which is a petition for certiorari; and (3) that the writ of preliminary injunction issued by DARAB in DSCA No. 0252 was null and void for having been issued in violation of the temporary restraining order.

The Supreme Court's Disposition

The Supreme Court affirmed the Court of Appeals' ruling that DARAB did not have jurisdiction to entertain Land Bank's petition for certiorari and denied the petition. The Court however accepted DARAB's explanation for participating in the appellate proceedings and did not sustain the Court of Appeals' prohibition against DARAB filing a comment.

Legal Basis: Jurisdiction to Issue Extraordinary Writs

The Court reiterated that jurisdiction to issue extraordinary writs such as certiorari, prohibition, and mandamus involves the exercise of original jurisdiction that must be expressly conferred by the Constitution or by law and is not to be implied. The Court observed that while the DARAB was created by Section 17 of Executive Order No. 229 and Section 13 of Executive Order No. 129-A as the DAR's quasi-judicial arm, and while Section 50 of R.A. No. 6657 vested the DAR with primary jurisdiction to adjudicate agrarian matters and broad powers to adopt uniform rules of procedure, those statutory and executive provisions did not expressly confer upon DARAB authority to issue extraordinary writs by way of original jurisdiction.

Legal Basis: Limits of Rule-Making and Delegation

The Court explained that the grant of adjudicatory power to a quasi-judicial agency is limited and special, defined by its enabling statutes. The DAR's delegation of authority to RARADs and PARADs under the DARAB Rules of Procedure did not transform DARAB into a regular court with all inherent powers to issue extraordinary writs. The Court emphasized that rules of procedure are remedial and concern practice and pleadings; they do not confer substantive jurisdiction where none exists by statute or constitutional grant.

Application of the DARAB Rules on Timeliness of Judicial Recourse

The Court relied on Rule XIII, Section 11 of the DARAB Rules of Procedure, which required a party dissatisfied with RARAD's preliminary land valuation to bring the matter directly to the regional trial courts designated as special agrarian courts within fifteen days from receipt of notice. Citing Philippine Veterans Bank vs. Court of Appeals, the Court noted that the fifteen-day reglementary period is jurisdictional and that Land Bank's filing on April 20, 2001 was beyond fifteen days from receipt of the RARAD denial on March 26, 2001;

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