Case Summary (G.R. No. 108000)
Antecedents
Suntay owned a total of 3,682.0285 hectares of land in Sta. Lucia, Sablayan, Occidental Mindoro. In 1972, 948.1911 hectares of his land were expropriated by the Department of Agrarian Reform (DAR) at a valuation of approximately P4.5 million. Displeased with this valuation, Suntay filed for the determination of just compensation with the Office of the Regional Agrarian Reform Adjudicator (RARAD), and RARAD MiAas eventually ruled that the just compensation should be over P157 million, which Land Bank contested.
Jurisdictional Issues
The central legal issue concerned the jurisdiction over just compensation determinations. The Supreme Court clarified that under Republic Act No. 6657 (Comprehensive Agrarian Reform Law), only the RTC, acting as a Special Agrarian Court, possesses original and exclusive jurisdiction to determine just compensation. It concluded that any attempt to authorize DARAB adjudicators to exercise this function is void and contrary to the law.
Proceedings History
Following the RARAD’s decision, various controversies arose regarding the implementation of the ruling, leading Land Bank to file a petition in the RTC, which was ultimately dismissed on grounds that the filing was beyond the reglementary period for judicial determination of just compensation. Land Bank’s arguments that the RTC's dismissal was improper led to multiple appeals and motions across courts, culminating in the dismissal of one of its petitions by the Court of Appeals on the grounds of mootness.
Supreme Court's Ruling on Legal Principles
The Supreme Court found merit in Land Bank’s appeal, stating that the dismissal of its petition by the Court of Appeals for being moot and academic was unwarranted due to various principal exceptions to the moot-and-academic doctrine, including the need for definitive resolution to avoid future delays and confusion regarding rights between parties.
Review of RARAD’s October 30, 2008 Order
The Court scrutinized the validity of RARAD MiAas’s order on October 30, 2008, directing the resumption of the ex parte execution of the earlier writ without substantive lawful basis. It noted that there were no valid existing proceedings left to resume due to the previous quashing of execution actions in connection with its prior orders, thus declaring the execution acts as legally ineffective.
Manner of Execution
The manner in which the execution was carried out violated pertinent laws and disregarded the process stipulated in the CARP. Specifically, the failure of the DARAB sheriffs to confirm whether the assets levied formed part of the Agrarian Reform Fund amounted to grave procedural irregularities.
Land Bank's Rights Over Dividends
Land Bank is entitled to all dividends from its shares of MERALCO, as the acts taken against them were rendered null and void, reinforcing its ownership rights amidst
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Background of the Case
- The case involves the Land Bank of the Philippines (Petitioner) and Federico Suntay (Respondent), represented by his assignee, Josefina Lubrica.
- The original and exclusive jurisdiction to determine just compensation under Republic Act No. 6657 (Comprehensive Agrarian Reform Law or CARL) is vested in the Regional Trial Court (RTC) as a Special Agrarian Court.
- The Department of Agrarian Reform Adjudication Board (DARAB) does not have the authority to transfer this jurisdiction or to convert the RTC's original jurisdiction into appellate jurisdiction.
- The Supreme Court granted the petition for review and reversed the decision of the Court of Appeals dated June 5, 2009, which dismissed the Land Bank's petition for certiorari as moot and academic.
Antecedents
- Federico Suntay owned 3,682.0285 hectares of land in Sta. Lucia, Sablayan, Occidental Mindoro.
- In 1972, 948.1911 hectares of his land were expropriated under Presidential Decree No. 27.
- The value of the expropriated land was initially set at P4,497.50 per hectare, totaling P4,251,141.68.
- Suntay contested this valuation and filed for a determination of just compensation with the Office of the Regional Agrarian Reform Adjudicator (RARAD).
- RARAD MiAas determined the compensation to be P157,541,951.30, which Land Bank sought to contest in court.
Proceedings and Rulings
- Land Bank filed a petition in the RTC for judicial determination of just compensation, which was dismissed for being filed beyond the