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PHILIPPINE VETERANS BANK v. CA

FACTS:

The petitioner, Philippine Veterans Bank, owned four parcels of land in Tagum, Davao, which were taken by the Department of Agrarian Reform for distribution to landless farmers under the Comprehensive Agrarian Reform Program. Dissatisfied with the valuation of the land made by respondents Land Bank of the Philippines and the Department of Agrarian Reform Adjudication Board (DARAB), petitioner filed a petition for a determination of the just compensation for its property. The petition was filed beyond the 15-day reglementary period for filing appeals from the orders of the DARAB, and thus, the Regional Trial Court, Branch 2, Tagum, Davao dismissed the petition. The dismissal was affirmed by the Court of Appeals. Petitioner argues that the petition for the judicial fixing of just compensation should be filed within the period provided in Rule XIII of the DARAB Rules of Procedure.

ISSUES:

  1. Should a petition for the judicial fixing of just compensation before the Special Agrarian Court be filed within the period provided in Rule XIII?

RULING:

  1. The Court of Appeals affirmed the dismissal of the petition for judicial determination of just compensation on the ground that it was filed beyond the 15-day reglementary period for filing appeals from the orders of the Department of Agrarian Reform Adjudication Board (DARAB). The Court held that jurisdiction over land valuation cases is lodged in the DARAB and that the decision of the Adjudicator on land valuation and preliminary determination and payment of just compensation shall be brought directly to the Regional Trial Court designated as Special Agrarian Courts within fifteen (15) days from receipt of the notice thereof. Since the petitioner failed to file the petition within the prescribed period, the dismissal of the petition by the trial court for having been filed out of time was held not to be in error.

PRINCIPLES:

  • The Department of Agrarian Reform Adjudication Board has primary and exclusive jurisdiction, both original and appellate, to determine and adjudicate all agrarian disputes, including the valuation of land and determination and payment of just compensation.

  • Petitions for the judicial fixing of just compensation before the Special Agrarian Courts must be exercised within the period provided in Rule XIII, Section 11 of the DARAB Rules of Procedure.