Title
Land Bank of the Philippines vs. Suntay
Case
G.R. No. 188376
Decision Date
Dec 14, 2011
Landowner disputes DAR's land valuation; SC rules RTC has exclusive jurisdiction over just compensation, nullifies DARAB's finality claims.
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Case Summary (G.R. No. 188376)

Jurisdiction Over Just Compensation

  • The Supreme Court affirmed that the Regional Trial Court (RTC) has original and exclusive jurisdiction to determine just compensation under Republic Act No. 6657 (Comprehensive Agrarian Reform Law).
  • Any attempt to transfer this jurisdiction to the Department of Agrarian Reform Adjudication Board (DARAB) is void and contrary to the law.
  • DARAB adjudicators can only make preliminary determinations regarding reasonable compensation, while the RTC retains the ultimate authority to decide on just compensation.

Background of the Case

  • Federico Suntay owned 3,682.0285 hectares of land in Occidental Mindoro, of which 948.1911 hectares were expropriated by the Department of Agrarian Reform (DAR) in 1972.
  • The initial valuation of the expropriated land was set at P4,497.50 per hectare, totaling P4,251,141.68, which Suntay rejected.
  • Suntay filed a petition for determination of just compensation with the Regional Agrarian Reform Adjudicator (RARAD), which resulted in a decision awarding him P157,541,951.30.

Proceedings in the RTC

  • Land Bank filed a petition in the RTC for judicial determination of just compensation, seeking to have the compensation fixed at the original valuation.
  • Despite the ongoing RTC case, RARAD issued an order declaring its earlier decision final and executory, which Land Bank contested.
  • Land Bank subsequently filed a petition for certiorari in DARAB to nullify RARAD's orders, which led to a series of legal disputes.

Court of Appeals Rulings

  • The Court of Appeals initially dismissed Land Bank's petition for certiorari as moot and academic, citing the finality of RARAD's decision.
  • However, the CA's ruling was challenged, leading to further appeals and clarifications regarding the jurisdiction and authority of the RTC and DARAB.

Supreme Court's Decision in DARAB v. Lubrica

  • The Supreme Court ruled that DARAB lacked jurisdiction over special civil actions for certiorari, affirming that the RTC has original jurisdiction over just compensation cases.
  • The Court emphasized that the jurisdiction of the RTC cannot be converted into appellate jurisdiction over administrative decisions.

Land Bank's Appeal and Subsequent Developments

  • Land Bank's appeal against the RTC's dismissal of its petition for just compensation was granted, and the RTC was ordered to continue proceedings to determine just compensation.
  • The Court clarified that the RTC's dismissal was erroneous as it treated the petition as an appeal rather than an original action.

Execution of RARAD's Orders

  • RARAD's orders for execution were deemed invalid as they did not comply with the legal requirements for just compensation under the CARP.
  • The Court found that the execution of the writs against Land Bank's assets was unlawful, as the assets were not part of the Agrarian Reform Fund (ARF).

Conclusion and Orders

  • The Supreme Court granted Land Bank's petition for review, reversing the CA...continue reading

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