Case Summary (G.R. No. 205128)
Applicable Law and Procedural Rules
1987 Philippine Constitution (Article VIII — judicial power); Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988), Section 16(d) and Section 50; Executive Orders Nos. 229 and 129‑A (delegation and administrative framework for DAR/DARAB); DARAB rules of procedure (1989, 1994, 2003, 2009); Rule 65 (1997 Rules of Civil Procedure) on certiorari; Rule 45 (1997 Rules) as procedural vehicle for review.
Factual Background — Land Offer, Valuation and Adjudication
Eliza Zoleta voluntarily offered for sale to the government a parcel (approx. 136 hectares) covered by TCT No. T‑87673. Pursuant to Executive Order No. 405, Landbank valued 125.4704 hectares as CARP‑covered at P3,986,639.57 and deposited that amount in Eliza’s name. Eliza rejected the valuation and the matter proceeded to DAR summary administrative proceedings under RA 6657 §16(d). On October 3, 2000, RARAD Conchita C. MiAas fixed just compensation at P8,938,757.72.
Procedural History — Competing Remedies and Enforcement Steps
Dissatisfied, Landbank filed a petition for just compensation in the Regional Trial Court (Special Agrarian Court) on November 7, 2000. Eliza moved for execution on November 9, 2000; RARAD granted the motion on January 16, 2001 and issued a writ of execution; an alias writ was issued on February 15, 2001 and enforcement steps (garnishment/levy) followed. Landbank sought quashal and interim restraining relief from the Special Agrarian Court but the court denied relief because DARAB was not impleaded. Landbank then filed, on April 2, 2001, a pleading styled as a “petition for certiorari” before DARAB pursuant to the DARAB New Rules of Procedure (1994).
DARAB Action and Subsequent Appeals
By Resolution dated May 12, 2006, DARAB granted Landbank’s petition for certiorari and annulled RARAD’s January 16, 2001 order and the February 15, 2001 alias writ of execution. Petitioners (the heirs) filed a Petition for Certiorari and Prohibition under Rule 65 before the Court of Appeals; the Court of Appeals, by its July 23, 2012 Decision and January 9, 2013 Resolution denying reconsideration, sustained DARAB’s exercise of authority based on its supervisory and appellate powers over RARAD/PARAD. The heirs then sought review by petition for review on certiorari (Rule 45) to the Supreme Court.
Issue Presented
Whether DARAB acted properly in issuing the May 12, 2006 Resolution granting Landbank’s petition for certiorari and annulling the RARAD order and alias writ of execution.
Holding
DARAB’s grant of Landbank’s petition for certiorari was improper. DARAB, as an administrative agency exercising quasi‑judicial functions but not vested with consummate judicial power, may not issue writs of certiorari; its purported exercise of certiorari power via its procedural rules was an unconstitutional usurpation of judicial power and a grave abuse of discretion. The Court granted the petition for review, reversed and set aside the Court of Appeals’ decisions, and ordered DARAB to dismiss Landbank’s petition for certiorari (DSCA 0219).
Jurisprudential and Constitutional Rationale — Nature of Certiorari
The Court reiterated established doctrine that the writ of certiorari is an incident of judicial review and historically a prerogative writ issued by superior courts (King’s Bench origin). Under Article VIII, Section 1 of the 1987 Constitution, judicial power is vested exclusively in the Judiciary; the power to determine whether a public officer or tribunal acted without or in excess of jurisdiction (or with grave abuse of discretion amounting to lack or excess of jurisdiction) is a judicial function. Rule 65 of the Rules of Court prescribes certiorari’s requisites: (1) directed against a tribunal, board or officer exercising judicial/quasi‑judicial functions; (2) action without/excess of jurisdiction or grave abuse of discretion; and (3) absence of appeal or plain, speedy, and adequate remedy.
Nature of Administrative Quasi‑Judicial Power and Its Limits
Administrative agencies (including DAR and DARAB) belong to the Executive and, although vested with quasi‑legislative and quasi‑judicial functions by statute, exercise only limited adjudicatory powers as defined by their enabling laws. Quasi‑judicial power allows determination of facts and application of legislative policy within statutory bounds, but it does not include the plenary judicial power to issue prerogative writs of judicial review such as certiorari. A grant of original jurisdiction to issue special civil actions must be conferred expressly by the Constitution or by law; rules of procedure cannot create substantive jurisdiction.
Analysis of DARAB’s Authority and Its Rules
DARAB’s earlier rules (1989 and 1994) provided mechanisms for Board review of RARAD/PARAD decisions and in the 1994 Rules referenced review “upon a verified petition for certiorari.” DARAB relied on its supervisory and appellate jurisdiction over regional/provincial adjudicators to justify issuing certiorari relief. The Court held that supervisory authority over subordinate adjudicators does not equate to judicial power to issue certiorari; exercise of such supervisory authority must remain within administrative control and cannot transmute an administrative body into a court empowered to decide jurisdictional controversies. DARAB’s attempt to con
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Procedural History
- Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Civil Procedure filed with the Supreme Court; G.R. No. 205128, decided August 9, 2017 by the Second Division, Decision penned by Justice Leonen.
- Underlying DARAB Resolution dated May 12, 2006 (docketed DSCA 0219) granted Land Bank of the Philippines’ (“Landbank”) pleading denominated a “petition for certiorari pursuant to paragraph 2, Section 3, Rule VIII of the DARAB New Rules of Procedure” and annulled the January 16, 2001 Order and the February 15, 2001 Alias Writ of Execution issued by Regional Adjudicator Conchita C. MiAas.
- Petitioners (heirs of Eliza Q. Zoleta) filed a Petition for Certiorari and Prohibition under Rule 65, R.R.C.P., before the Court of Appeals challenging DARAB’s May 12, 2006 Resolution; CA Decision dated July 23, 2012 denied petitioners’ challenge, holding DARAB acted within its supervisory/appellate authority; CA Resolution dated January 9, 2013 denied petitioners’ Motion for Reconsideration.
- Supreme Court granted the present Petition for Review on Certiorari, reversed and set aside the Court of Appeals’ July 23, 2012 Decision and January 9, 2013 Resolution, and ordered DARAB to dismiss DSCA 0219.
Factual Background
- On September 29, 1996 Eliza Zoleta voluntarily offered for sale to the government, under the Comprehensive Agrarian Reform Program, a 136-hectare parcel covered by TCT No. T-87673 located in Barangay Casay, San Francisco, Quezon.
- Pursuant to Executive Order No. 405, Landbank valued the portion covered by CARP at 125.4704 hectares and placed the value at P3,986,639.57, then deposited this amount in Eliza’s name.
- Eliza rejected Landbank’s valuation; matter was endorsed to the Provincial Agrarian Reform Adjudicator (PARAD) of Quezon II, then transferred to the Regional Agrarian Reform Adjudicator (RARAD) upon Eliza’s manifestation that the amount involved exceeded PARAD’s jurisdiction.
- RARAD conducted summary administrative proceedings under Section 16(d), R.A. No. 6657, and on October 3, 2000 Regional Adjudicator MiAas rendered a Decision fixing just compensation at P8,938,757.72.
- Landbank filed a Petition for Just Compensation before the Regional Trial Court acting as Special Agrarian Court on November 7, 2000; on November 9, 2000 Eliza filed a Motion for Execution before RARAD to implement the October 3, 2000 Decision.
- On January 16, 2001 RARAD granted Eliza’s motion and issued an order directing issuance of a writ of execution; returned unsatisfied and an alias writ of execution issued February 15, 2001; DARAB Sheriff issued Notices of Garnishment and Levy on Personal Property.
- Landbank sought quashal before the Special Agrarian Court and interim TRO; Special Agrarian Court denied relief (Resolution dated March 27, 2001) because DARAB had not been impleaded by Landbank, hence the court had no jurisdiction over DARAB.
- On April 2, 2001 Landbank filed before DARAB its pleading styled a “petition for certiorari” asserting “grave abuse of discretion amounting to lack or in excess of jurisdiction” by Regional Adjudicator MiAas in issuing the January 16, 2001 Order and the February 15, 2001 Alias Writ of Execution; petition docketed DSCA 0219.
- DARAB, by Resolution dated May 12, 2006 (docketed DSCA 0219; penned by Asst. Sec. Edgar A. Igano with concurrence of several DAR officials), granted Landbank’s petition and “annulled” the January 16, 2001 Order and February 15, 2001 Alias Writ of Execution.
- Petitioners (substituted heirs of Eliza Zoleta) filed Rule 65 certiorari and prohibition before the Court of Appeals, which in a July 23, 2012 Decision upheld DARAB’s action under its supervisory/appellate jurisdiction; January 9, 2013 Motion for Reconsideration denied; Supreme Court review followed.
Issues Presented
- Whether it was proper for DARAB to issue its May 12, 2006 Resolution granting Landbank’s petition denominated a petition for certiorari, thereby annulling the RARAD’s January 16, 2001 Order and February 15, 2001 Alias Writ of Execution.
- Subsidiary questions: whether DARAB, as an administrative agency, possesses power to issue writs of certiorari; whether DARAB’s rules of procedure (notably the 1994 Rules) can confer certiorari jurisdiction; whether DARAB’s supervisory/appellate authority over RARADs suffices to permit issuance of writs of certiorari to correct jurisdictional errors.
Statutory and Rule Provisions Cited
- 1987 Constitution, Article VIII, Section 1 — judicial power vested in the Supreme Court and such lower courts as may be established by law; includes duty to determine whether there has been grave abuse of discretion amounting to lack or excess of jurisdiction.
- Rule 65, Section 1, Rules of Court (1997 Rules of Civil Procedure) — defines petition for certiorari and requisites for issuing writ of certiorari (tribunal exercising judicial/quasi-judicial functions; acted without or in excess of jurisdiction or with grave abuse; no appeal or plain, speedy, adequate remedy).
- Rule 45, Rules of Court — petition for review on certiorari (procedural vehicle used in this Supreme Court appeal).
- Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988):
- Section 16(d) — summary administrative proceedings to determine compensation upon rejection or failure to reply; deadlines provided.
- Section 50 — quasi-judicial powers of the Department of Agrarian Reform (DAR), exclusive original jurisdiction over agrarian matters; decisions immediately executory; power to adopt uniform rules of procedure.
- Executive Order No. 405 — vesting Landbank with primary responsibility to determine land valuation and compensation under R.A. No. 6657 (1990).
- Executive Order No. 229 — vested DAR with quasi-judicial powers to resolve agrarian reform cases, allowed appeal mechanism to Regional Trial Courts; Section 17 spelled out quasi-judicial powers.
- Executive Order No. 129-A — created the Agrarian Reform Adjudication Board (DARAB); Section 13 allows delegation of the Board’s powers to regional offices subject to rules/regulations.
- DARAB Rules of Procedure:
- 1989 Rules — delegated adjudicatory powers to RARADs and PARADs subject to “functional supervision”; provided for review by the Board upon verified petition for review on certiorari (Rule VIII, Section 3).
- 1994 DARAB New Rules of Procedure — Rule VIII, Section 3 (Totality of Case Assigned) provided Board may modify/reverse interlocutory orders “upon a verified petition for certiorari which cannot be entertained without filing a motion for reconsideration with the Adjudicator a quo within five (5) days,” and Rule XIV, Section 1 authorized certiorari to the Co