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DEPARTMENT OF AGRARIAN REFORM v. ROBERTO J. CUENCA

FACTS:

The case involves a Petition for Review assailing the decision of the Court of Appeals in a case involving the implementation of the Comprehensive Agrarian Reform Program (CARP). The petitioner, Department of Agrarian Reform (DAR), argues that all controversies related to the implementation of CARP fall under the jurisdiction of DAR, even if they raise legal or constitutional questions. The respondent, Roberto Cuenca, is the registered owner of a parcel of land covered by CARP. He filed a complaint seeking the annulment of the Notice of Coverage for his landholding, claiming that the implementation of CARP on his land is no longer authorized by law and that Executive Order No. 405, which determines the value of the land, is unconstitutional. The Municipal Agrarian Reform Officer (MARO) filed a motion to dismiss the complaint on the ground that the court has no jurisdiction over the case. The trial court issued a Temporary Restraining Order (TRO) and a Writ of Preliminary Injunction, enjoining the MARO from implementing the Notice of Coverage. The DAR filed a petition for certiorari with the Court of Appeals, arguing that the trial court's issuance of the TRO and Writ of Preliminary Injunction is a violation of the law granting DAR immunity from court interference.

This case involves a dispute over the jurisdiction of the court to hear a complaint for the annulment of a Notice of Coverage under the Comprehensive Agrarian Reform Program (CARP) and the constitutionality of Executive Order No. 405. The petitioner argues that lower courts are prohibited by law from issuing injunctions against the Department of Agrarian Reform (DAR) in the implementation of the Notice of Coverage. The petitioner also contends that the court a quo has no jurisdiction over the case as it is purely agrarian in nature. The Court of Appeals ruled that the Regional Trial Court (RTC) has jurisdiction over the case and that the court a quo had the authority to issue the injunction order. The appellate court also held that the prohibition against injunctions in certain statutes only applies to administrative acts, controversies involving facts, or the exercise of discretion in technical cases. The petitioner raises two issues in the Memorandum: the jurisdiction of the trial court and the violation of Sections 55 and 68 of Republic Act No. 6657. The Supreme Court ruled that the complaint for the annulment of the Notice of Coverage involves an agrarian reform matter and falls within the jurisdiction of the DAR. However, the Court also acknowledged that conflicts over jurisdiction in agrarian disputes have been a struggle and that jurisdiction is conferred by law. The Court held that since the complaint primarily assails the constitutionality of EO 405, which is a purely legal issue, it falls within the jurisdiction of the RTC.

ISSUES:

  1. Whether Section 12 of Presidential Decree No. 946 providing the CARs with original and exclusive jurisdiction over agrarian reform matters was repealed by Executive Order No. 229.

  2. Whether the Department of Agrarian Reform (DAR) has the power to approve or disapprove the conversion of agricultural lands for non-agricultural uses.

  3. Whether or not the Department of Agrarian Reform (DAR) has jurisdiction over cases involving the implementation of agrarian reform laws.

  4. Whether or not the Regional Trial Courts (RTCs) have jurisdiction over agrarian reform matters.

  5. Whether or not the Regional Trial Court has jurisdiction over the case involving the constitutionality of Executive Order No. 405 (EO 405).

  6. Whether or not the Regional Trial Court has the authority to issue a writ of preliminary injunction.

RULING:

  1. Yes, Section 12 of Presidential Decree No. 946 was repealed by Executive Order No. 229. In Quismundo v. CA, it was held that the provision of Executive Order No. 229 granting the DAR with exclusive jurisdiction over all matters involving the implementation of agrarian reform repealed the original and exclusive jurisdiction of the CARs provided in Presidential Decree No. 946.

  2. Yes, the DAR has the power to approve or disapprove the conversion of agricultural lands for non-agricultural uses. Under Section 5(l) of Executive Order No. 129-A, the DAR was given exclusive authority to approve or disapprove the conversion of agricultural lands into non-agricultural uses.

  3. The DAR has original and exclusive jurisdiction over all matters involving the implementation of agrarian reform, except those falling under the exclusive jurisdiction of the Department of Agriculture (DA) and the Department of Environment and Natural Resources (DENR).

  4. RTCs designated as Special Agrarian Courts have original and exclusive jurisdiction over petitions for the determination of just compensation to landowners and the prosecution of all criminal offenses under the agrarian reform laws.

  5. The Regional Trial Court does not have jurisdiction over the case involving the constitutionality of EO 405. The issuance of the Notice of Coverage, which is the subject matter of the case, is a necessary step towards the acquisition of private land under the Comprehensive Agrarian Reform Program (CARP). The implementation of CARP falls under the quasi-judicial jurisdiction of the Department of Agrarian Reform (DAR). The court cannot oust the DAR of its authority by attaching a constitutional or legal dimension to the issue. The court should refrain from resolving matters that demand the special competence of administrative agencies, even if the questions involved are also judicial in character.

  6. The Regional Trial Court does not have the authority to issue a writ of preliminary injunction. The court's authority is expressly prohibited by Section 68 of Republic Act No. 6657. This provision grants immunity to government agencies implementing the CARP from any injunction, restraining order, prohibition, or mandamus issued by lower courts.

PRINCIPLES:

  • The jurisdiction of the CARs over agrarian reform matters was repealed by Executive Order No. 229, which granted the DAR exclusive jurisdiction over the implementation of agrarian reform. (Quismundo v. CA)

  • The DAR has the power to approve or disapprove the conversion of agricultural lands for non-agricultural uses. (Executive Order No. 129-A)

  • The DAR has primary jurisdiction to determine and adjudicate agrarian reform matters and has the power to summon witnesses, administer oaths, take testimony, require submission of reports, compel the production of books and documents, and issue subpoena and subpoena duces tecum.

  • The Special Agrarian Courts, which are RTCs designated as such, have original and exclusive jurisdiction over petitions for the determination of just compensation to landowners and the prosecution of all criminal offenses under the agrarian reform laws.

  • The RTCs have not been completely divested of jurisdiction over agrarian reform matters.

  • The implementation of the Comprehensive Agrarian Reform Program falls under the quasi-judicial jurisdiction of the Department of Agrarian Reform.

  • Courts should refrain from resolving controversies that demand the special competence of administrative agencies.

  • Government agencies implementing the CARP are granted immunity from any injunction, restraining order, prohibition, or mandamus issued by lower courts.