G.R. No. 205128 - Heirs of Zoleta vs. Land Bank of the Philippines

Case Summary (G.R. No. 205128)

Factual Background

Eliza Zoleta offered her land for sale under CARP. Landbank valued 125.4704 hectares at ₱3,986,639.57 and deposited this amount in her name. Disputing that valuation, Eliza’s case was transferred from the Provincial to the Regional Agrarian Reform Adjudicator (RARAD), which, after summary proceedings under Section 16(d) of RA 6657, fixed just compensation at ₱8,938,757.72 on October 3, 2000.

Enforcement and Initial Relief Efforts

Unhappy with the RARAD decision, Landbank petitioned the Special Agrarian Court for just compensation on November 7, 2000. Meanwhile, Eliza secured an order and writ of execution on January 16 and February 15, 2001, respectively, but the writs remained unsatisfied. Landbank’s attempt to quash those writs before the Special Agrarian Court failed for lack of DARAB as a party.

DARAB Proceeding on Certiorari

On April 2, 2001, Landbank filed a “petition for certiorari” under paragraph 2, Section 3, Rule VIII of the 1994 DARAB Rules, alleging grave abuse of discretion by RARAD in issuing the execution writs. By its May 12, 2006 Resolution, DARAB granted that petition and annulled the RARAD’s January 16 order and February 15 alias writ of execution.

Court of Appeals Review

Petitioners secured a Rule 65 certiorari before the Court of Appeals, which in a July 23, 2012 Decision and January 9, 2013 Resolution upheld DARAB’s action, citing its supervisory and appellate jurisdiction over RARADs under CARL and related rules.

Legal Issue

Whether an administrative body such as DARAB may issue a writ of certiorari—an inherently judicial remedy—absent an express constitutional or statutory grant.

Constitutional and Statutory Framework

• 1987 Constitution, Article VIII, Section 1: Judicial power is vested exclusively in courts established by law; it includes the duty to remedy grave abuse of discretion by any government instrumentality.
• Rule 65, 1997 Rules of Civil Procedure: Defines certiorari as an extraordinary remedy against tribunals exercising judicial or quasi-judicial functions acting without or in excess of jurisdiction or with grave abuse of discretion, when no adequate remedy exists.

Nature and Origin of Certiorari

Derived from the English King’s prerogative writ, adopted in U.S. and Philippine jurisprudence to correct inferior tribunals’ excesses. It lies only to review judicial or quasi-judicial acts and may be issued solely by courts expressly empowered by Constitution or statute.

Separation of Powers and Quasi-Judicial Agencies

Administrative agencies exercise executive, legislative and limited quasi-judicial powers incidental to their enabling statutes. They lack consummate judicial authority; controversies over jurisdictional excess or grave abuse demand legal interpretation and enforcement of rights—functions reserved for courts.

Agrarian Reform Adjudication Scheme

E.O. 229 and RA 6657 vested DAR with primary quasi-judicial jurisdiction, delegated to RARADs and PARADs, and authorized DARAB to exercise appellate supervision. The 1989 and 1994 DARAB Rules mentioned certiorari as a vehicle for review