G.R. No. 122256 - Republic vs. Court of Appeals

Acil Corporation owned land in Linoan, Montevista, Davao del Norte, which was taken by the government under the Comprehensive Agrarian Reform Law (R.A. No. 6657).
The government canceled Acil Corporation's certificates of title and issued new ones to farmer-beneficiaries.
The Land Bank of the Philippines (LBP) initially valued the land at P19,312.24 per hectare for riceland and P4,267.68 per hectare for brushland, totaling P439,105.39.
However, based on a lower "Fair Value Acceptable to Landowner" stated in Acil Corporation's LISTASAKA, LBP later valued the land at P15,311.79 per hectare, totaling P390,557.84.

Acil Corporation rejected the government's offer, citing higher valuations for similar nearby lands at P24,717.40 per hectare.
The matter was brought before the Provincial Agrarian Reform Adjudicator (PARAD), which upheld LBP's valuation on October 8, 1992.
Subsequently, Acil Corporation filed a Petition for Just Compensation in the Regional Trial Court (RTC) of Tagum, Davao del Norte, seeking P24,717.40 per hectare.

The RTC dismissed Acil Corporation's petition, ruling that it should have appealed to the Department of Agrarian Reform Adjudication Board (DARAB) first, as per DARAB's Revised Rules of Procedure.
The RTC also noted that the petition was filed more than fifteen days after the PARAD's decision, violating DARAB's procedural rules.
Acil Corporation's motion for reconsideration was denied on October 13, 1994.

Acil Corporation filed a petition for certiorari with the Court of Appeals, arguing that the RTC had exclusive and original jurisdiction over just compensation claims under R.A. No. 6657.
The Court of Appeals agreed, setting aside the RTC's dismissal and remanding the case for further proceedings.

The government, represented by the Department of Agrarian Reform, filed a petition for review, questioning whether an appeal to the DARAB was necessary before resorting to the RTC for just compensation claims.
The petitioners argued that R.A. No. 6657 grants the DAR primary jurisdiction over agrarian reform matters, including just compensation.

The Supreme Court analyzed the jurisdictional provisions of R.A. No. 6657, particularly Sections 50 and 57.
Section 50 grants the DAR primary jurisdiction over agrarian reform matters, while Section 57 specifically grants Special Agrarian Courts (RTCs) original and exclusive jurisdiction over just compensation petitions.
The Court emphasized that the determination of just compensation is a judicial function, not an administrative one.

Petitioners cited DARAB Rules of Procedure to support their claim that decisions of agrarian reform adjudicators could only be appealed to the DARAB.
However, the Supreme Court noted that procedural rules cannot confer jurisdiction; only statutes can.
The new DARAB rules, adopted on May 30, 1994, allow landowners to bring just...continue reading