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LAND BANK OF PHILIPPINES v. RENE RALLA BELISTA

FACTS:

Spouses Pablo Ralla and Carmen Munoz Ralla donated eight parcels of land in Ligao, Albay to their daughter, Rene Ralla Belista. These parcels of land were placed under the coverage of the Comprehensive Agrarian Reform Program (CARP) by the Department of Agrarian Reform (DAR).

Believing that her lots were undervalued, Belista filed a Petition for Valuation and Payment of Just Compensation against the Land Bank of the Philippines (LBP) before the DARAB-Regional Adjudicator for Region V (RARAD-V).

On July 7, 2003, RARAD-V issued a Decision in favor of Belista, fixing the just compensation at P2,896,408.91. Both parties filed motions for reconsideration, and RARAD-V issued an Order on October 8, 2003, modifying the valuation claim to P2,540,211.58.

Petitioner LBP filed an original Petition for Determination of Just Compensation at the Regional Trial Court (RTC), but the court dismissed the case for failure to exhaust administrative remedies and comply with the DARAB Rules of Procedure.

Petitioner LBP filed a Motion for Reconsideration, which was denied. Petitioner then filed a petition for review before the Court of Appeals (CA), which affirmed the dismissal of the petition.

Petitioner now seeks the annulment of the CA decision, arguing that it did not violate the doctrine of non-exhaustion of administrative remedies and that the applicable rules are the 1994 DARAB Rules of Procedure, not the 2003 DARAB Rules.

The main issue is whether the decision of the Adjudicator must first be appealed to the DARAB before resorting to the RTC sitting as SAC.

ISSUES:

  1. Whether it is necessary to appeal the decision of the Adjudicator to the DARAB before resorting to the RTC sitting as SAC in cases involving claims for just compensation under RA No. 6657.

  2. Whether the determination of just compensation for lands taken under the agrarian reform program is a function of the courts of justice.

  3. Whether the Regional Trial Court (RTC) has jurisdiction over petitions for the determination of just compensation for lands taken under agrarian reform.

RULING:

  1. The court rules in the negative. The jurisdiction on just compensation cases for the taking of lands under RA No. 6657 is vested in the courts. The Special Agrarian Courts, being Regional Trial Courts, have original and exclusive jurisdiction over all petitions for the determination of just compensation to landowners. The DAR, as an administrative agency, cannot be granted jurisdiction over cases of eminent domain and over criminal cases. The original and exclusive jurisdiction of the RTC, sitting as SAC, is upheld by the court in accordance with Section 57 of RA No. 6657. Therefore, there is no need to appeal to the DARAB before resorting to the RTC sitting as SAC in cases involving claims for just compensation.

  2. Yes, the determination of just compensation for lands taken under the agrarian reform program is a function of the courts of justice. The valuation of property or determination of just compensation in eminent domain proceedings is essentially a judicial function vested with the courts and not with administrative agencies.

  3. Yes, the RTC has jurisdiction over petitions for the determination of just compensation for lands taken under agrarian reform. The original and exclusive jurisdiction to determine just compensation is with the RTC, as provided by Section 57 of Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988). The DAR's role is limited to a preliminary determination of just compensation, which is subject to challenge before the courts.

PRINCIPLES:

  • The DAR has primary jurisdiction to determine and adjudicate agrarian reform matters and exclusive original jurisdiction over all matters involving the implementation of agrarian reform, except those falling under the exclusive jurisdiction of other agencies (DA and DENR).

  • The Special Agrarian Courts, which are Regional Trial Courts, have original and exclusive jurisdiction over all petitions for the determination of just compensation to landowners and the prosecution of all criminal offenses under RA No. 6657.

  • The valuation of property in eminent domain is essentially a judicial function that cannot be vested in administrative agencies.

  • The jurisdiction of the RTC, sitting as SAC, would be undermined if the DAR vested administrative officials with original jurisdiction in compensation cases and made the RTC an appellate court for the review of administrative decisions.

  • Direct resort to the SAC by private respondents is valid, as the original and exclusive jurisdiction to determine compensation cases is in the RTCs.

  • The determination of just compensation for lands taken under the agrarian reform program is a function of the courts of justice.

  • The original and exclusive jurisdiction to determine just compensation for lands taken under agrarian reform is with the regional trial courts.

  • The primary jurisdiction of the Department of Agrarian Reform (DAR) is to determine in a preliminary manner the just compensation for lands taken under the agrarian reform program, but such determination is subject to challenge before the courts.

  • Rules of procedure cannot confer jurisdiction on courts and administrative agencies. Jurisdiction over the subject matter is conferred by law.