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