Title
The Roman Catholic Bishop of Malolos, Inc. vs. Heirs of Marcos
Case
G.R. No. 225971
Decision Date
Jun 17, 2020
RCBMI, owner of land awarded to Marcos heirs under P.D. 27, contested CARP coverage. After decades of delays, Supreme Court ruled PARAD abused discretion, ordered execution of 1982 MAR Order.

Case Summary (G.R. No. 129015)

PARAD and DARAB litigation to recover possession

RCBMI filed a complaint before the PARAD on February 2, 1994, seeking a writ of preliminary injunction and damages. The PARAD ruled for RCBMI on July 24, 1995, ordering the heirs to vacate and declaring void any sales by the heirs. DARAB affirmed on October 25, 2001; reconsideration was denied October 24, 2002. The heirs appealed to the Court of Appeals, which denied their petition on May 26, 2004; the Entry of Judgment became final and executory on June 19, 2004. Despite final judgments, execution did not follow promptly.

Motion for writ of execution and prolonged delays

RCBMI filed a Motion for Issuance of Writ of Execution on March 10, 2008, seeking to enforce the 1982 MAR Order and subsequent final decisions. Instead of promptly issuing the writ as a ministerial act, PARAD required the heirs to comment and set hearings. The heirs opposed, invoking a supervening DAR proceeding placing the property under CARP coverage. The PARAD delayed resolution until after the DAR Secretary dismissed the coverage petition on May 5, 2011 (finding the property a fishpond and exempt from CARP). PARAD eventually granted RCBMI’s request by order dated February 17, 2012, but no writ issued immediately; RCBMI filed multiple motions to resolve. A writ was finally issued only after protracted steps, but the heirs then filed a Motion to Quash, arguing the five-year execution period under Section 4, Rule 20 of the 1989 DARAB Rules had lapsed. PARAD granted the Motion to Quash on August 19, 2015, holding enforcement would require an action; RCBMI’s motions for reconsideration were denied.

Proceedings before the Court of Appeals

RCBMI filed a Rule 65 petition (certiorari and mandamus) with the Court of Appeals on February 26, 2016, challenging PARAD’s quashal and seeking compelment to execute. The CA dismissed the petition on April 8, 2016 for non-exhaustion of administrative remedies, citing the 1989 and 2009 DARAB Rules provisions requiring appeal to the DARAB. The CA reasoned certiorari under Rule 65 is available only where no other plain, speedy, and adequate remedy exists; since appellate relief before DARAB was available, RCBMI should have pursued administrative appeal. A motion for reconsideration to the CA was denied on July 20, 2016.

Issues presented to the Supreme Court

  1. Whether the Court of Appeals erred in dismissing RCBMI’s Rule 65 petition for non-exhaustion of administrative remedies.
  2. Whether PARAD acted in excess of jurisdiction or committed grave abuse of discretion in granting the heirs’ Motion to Quash the writ of execution and denying RCBMI’s motions for reconsideration.

Governing procedural framework and applicable rules

The Supreme Court emphasized that because the PARAD proceedings began on February 2, 1994, the 1989 DARAB Revised Rules governed. Those rules were expressly designed to promote just, expeditious, and inexpensive adjudication of agrarian disputes, allow summary proceedings, and to be flexible and not bound by technicalities. Rule XII of the 1989 DARAB Rules (Execution) was central: Section 1 directed that execution shall issue upon a decision that finally disposes of the action and that execution shall issue as a matter of course upon certification that a decision has become final and executory; Section 2 made orders immediately executory regardless of appeal (subject to exceptions); Section 3 limited stays of execution only in specified circumstances.

Analysis on non-exhaustion of administrative remedies

The Court concluded the CA erred in dismissing RCBMI’s Rule 65 petition on non-exhaustion grounds. While exhaustion of administrative remedies is a general rule rooted in practical considerations, the doctrine admits exceptions. The Court identified the applicable exception here as unreasonable delay or official inaction that will irretrievably prejudice the complainant—i.e., the temporal exception. Given the exceptional and protracted delay (decisions dating from 1982 to execution efforts spanning decades), requiring RCBMI to pursue further administrative appeals would be futile and would defeat the doctrine’s rationale. The DARAB’s appellate jurisdiction is primarily merit-focused and would not have provided the immediate, ministerial relief RCBMI sought (compelling issuance of a writ of execution). The extreme delay and continued suspension of RCBMI’s rights amounted to prejudice sufficient to excuse exhaustion.

Analysis on PARAD’s alleged grave abuse of discretion and duty to execute

The Court found that PARAD committed grave abuse of discretion through unjustified delay. Under the 1989 DARAB Rules, execution should have been ministerial once the decisions became final and executory. RCBMI’s final CA judgment became final June 19, 2004; RCBMI sought execution March 10, 2008. PARAD did not promptly issue the writ but entertained oppositions and prolonged proceedings until February 17, 2012 and beyond. That delay, compounded by the heirs’ serial oppositions and PARAD’s inaction, produced an inexplicable and unacceptable suspension of execution and effectively nullified RCBMI’s final victories. The Court observed that litigation must terminate and that a final and executory judgment becomes immutable and unalterable; PARAD’s failure to promptly execute contravened the execution provisions of the 1989 Rules and the broader objectives of expeditious agrarian adjudication.

Disposition and relief granted

The Supreme Court granted the Petition for Review on Certiorari. It rever

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