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LAND BANK OF PHILIPPINES v. MAGDALENA QUILIT

FACTS:

In this case, petitioner Land Bank of the Philippines (LBP) filed a petition for review on certiorari before the Supreme Court, assailing the decision of the Court of Appeals (CA) denying its petition for review. The case originated from a petition for annulment of sale and redemption filed by respondents Mauricio Laoyan and Magdalena Quilit before the Regional Agrarian Reform Adjudicator (RARAD). The case involved two parcels of land previously owned by the Spouses Pedro and Erenita Tolding, which were later acquired by petitioner through foreclosure. The RARAD rendered a decision allowing the respondents to exercise their right of redemption. Petitioner filed a notice of appeal but it was denied and a writ of execution was issued. Petitioner filed a motion for reconsideration but it was also denied. Subsequently, petitioner filed a petition for certiorari with the Department of Agrarian Reform Adjudication Board (DARAB), which dismissed the petition for lack of jurisdiction. The CA upheld the dismissal, citing previous jurisprudence that the DARAB has limited jurisdiction and does not have authority over petitions for certiorari.

In this case, Land Bank of the Philippines (LBP) filed a petition for certiorari with the Department of Agrarian Reform Adjudication Board (DARAB) challenging the decision of the Regional Adjudication Board (RARAD) in a land valuation and payment dispute. The DARAB dismissed the petition for lack of jurisdiction, citing the absence of an express grant of jurisdiction to issue the writ of certiorari in the relevant laws, particularly Republic Act No. 6657, Executive Order No. 229, and Executive Order No. 129-A. The Court of Appeals (CA) upheld the DARAB's dismissal, stating that even if the 1994 DARAB New Rules of Procedure allowed the filing of a petition for certiorari with the DARAB, the DARAB may dismiss the petition if the petitioner fails to file a motion for reconsideration with the RARAD within the required period. Dissatisfied with the CA's decision, LBP filed a petition for review before the Supreme Court. The Supreme Court denied the petition, affirming the DARAB's lack of jurisdiction to issue the writ of certiorari. The Court emphasized that the DARAB is a quasi-judicial body with limited jurisdiction, and the absence of a specific statutory grant of jurisdiction to issue the extraordinary writ of certiorari prevents the DARAB from exercising jurisdiction over LBP's petition. The Court referred to a previous case involving LBP, Department of Agrarian Reform Adjudication Board v. Josefina Lubrica, which settled that the DARAB does not have the power to issue writs of certiorari. The Court also noted that the findings of facts of quasi-judicial agencies like the RARAD are generally accorded great weight and even finality in the absence of substantial showing of error.

ISSUES:

  1. Whether the DARAB has jurisdiction to issue the writ of certiorari.

  2. Whether the ruling in the case of Lubrica and Zoleta can be applied retroactively.

  3. Whether or not the ruling in Land Bank of the Philippines v. De Leon, which concerns the proper mode of appeal from decisions of Special Agrarian Courts, applies to the issue of the DARAB's jurisdiction over petitions for certiorari.

  4. Whether or not the DARAB has the power to issue writs of certiorari and rule on jurisdictional controversies.

  5. Whether the Court can examine and make a determinative finding on the issues raised by the petitioner, which are questions of fact.

  6. Whether the disallowance of the petitioner's notice of appeal signifies the disallowance of the appeal itself.

RULING:

  1. The DARAB does not have jurisdiction to issue the writ of certiorari. The DARAB, being a quasi-judicial body with limited jurisdiction, cannot exercise jurisdiction over a petition for certiorari. The power to issue writs of certiorari is an incident of judicial review, which the DARAB, as an administrative agency, is inherently incapable of doing. Therefore, the DARAB cannot issue the writ of certiorari to annul acts of the Provincial Agrarian Reform Adjudicator or Regional Agrarian Reform Adjudicator, even when it exercises supervisory powers over them.

  2. The ruling in the case of Lubrica and Zoleta can be applied retroactively. The fact that the petitions in Lubrica and Zoleta were filed before the promulgation of the ruling does not exempt them from the jurisdictional limitations of the DARAB. Therefore, the petitioner in this case cannot rely on the 1994 DARAB New Rules of Procedure to assert their right to file a petition for certiorari with the DARAB. The Comprehensive Agrarian Reform Law of 1988 does not confer the DARAB the authority to take cognizance of petitions for certiorari. The retroactive application of the ruling does not impair the petitioner's substantive right to question the DARAB's orders by way of certiorari.

  3. The Court ruled that the ruling in Land Bank of the Philippines v. De Leon does not apply to the issue of the DARAB's jurisdiction over petitions for certiorari. The ruling in De Leon pertains to the proper mode of appeal, while the present case involves an issue regarding the DARAB's jurisdiction. Therefore, the Court cannot simply apply the pronouncement in De Leon to the present case.

  4. The Court held that the DARAB does not have the power to issue writs of certiorari and rule on jurisdictional controversies. The DARAB is an administrative agency belonging to the Executive branch, while determining whether an action was made without or in excess of jurisdiction or with grave abuse of discretion is a judicial question. Administrative agencies, such as the DARAB, must recuse and yield to the courts of law in controversies involving jurisdictional issues. The DARAB's exercise of the certiorari power is an encroachment into the judiciary and violates the separation of powers. Therefore, the DARAB's exercise of certiorari powers is unconstitutional.

  5. The Court is not inclined to examine and make a determinative finding on the issues raised by the petitioner, which are questions of fact. The Court's function is not to review or evaluate the evidence presented by the parties, as it is not a trier of facts. The petition for review on certiorari under Rule 45 is limited to reviewing only errors of law and not of facts. The petitioner failed to show that the case falls under any of the exceptions to this rule.

  6. The disallowance of the petitioner's notice of appeal signifies the disallowance of the appeal itself. The petitioner should have elevated the matter through a special civil action under Rule 65. Since the petitioner failed to timely file its petition for certiorari with the proper appellate court within 60 days from the date of receipt of the order denying the notice of appeal, the said order remained valid and effective. Accordingly, the decision of the Regional Agrarian Reform Adjudication Board (RARAD) remains final and executory and beyond judicial review.

PRINCIPLES:

  • The DARAB, as a quasi-judicial body with limited jurisdiction, cannot exercise jurisdiction over a petition for certiorari.

  • The power to issue writs of certiorari is an incident of judicial review, which administrative agencies like the DARAB are inherently incapable of doing.

  • The rules of procedure adopted by the DARAB cover only rules on pleadings and practice, and do not grant it unbridled discretion to grant itself jurisdiction ordinarily conferred only by the Constitution or by law.

  • The lack of authority of the DARAB over special civil actions for certiorari is not only attributed to the absence of a statutory grant, but also to its inherent inability as a quasi-judicial agency.

  • The ruling in the cases of Lubrica and Zoleta, declaring that the DARAB cannot acquire jurisdiction over petitions for certiorari, applies retroactively.

  • The Comprehensive Agrarian Reform Law of 1988 does not confer the DARAB authority to take cognizance of petitions for certiorari.

  • Mere procedural rules cannot supplant a constitutional or statutory grant of jurisdiction.

  • Determining whether an action was made without or in excess of jurisdiction or with grave abuse of discretion is a judicial question.

  • Administrative agencies must recuse and yield to courts of law in controversies involving jurisdictional issues.

  • The exercise of the certiorari power by an administrative agency is an executive encroachment into the judiciary and violates the separation of powers.

  • Administrative agencies have no power to rule on jurisdictional controversies via petitions for certiorari.

  • The Court is not a trier of facts and is limited to reviewing only errors of law in a petition for review on certiorari under Rule 45.

  • There are exceptions to the rule of limited review of factual issues, such as when there is speculation, grave abuse of discretion, misapprehension of facts, conflicting findings, absence of citation of specific evidence, contradictions in findings, manifest overlooking of relevant facts, contrary findings between the trial court and the Court of Appeals, findings beyond the issues of the case, and findings contrary to the admissions of both parties.

  • The disallowance of a notice of appeal signifies the disallowance of the appeal itself. If a petitioner wishes to challenge the disallowance, the proper remedy is a petition for certiorari under Rule 65, which should be filed within 60 days from the receipt of the order. Failure to timely file the petition renders the order final and executory.