Land Bank vs. Villegas

LAND BANK OF THE PHILIPPINES v. GR No.
180384
VILLEGAS
March 26, 2010 Abad, J.
TOPIC IN SYLLABUS: Jurisdiction
SUMMARY: LBP filed cases for determination of just compensation
against Villegas and heirs of Noel before RTC Br. 32 of Dumaguete
City, the designated SAC of Negros Oriental. The subject lands were
located in Guihulngan City and Bayawan City, which are outside the
regular territorial jurisdiction of RTC Br. 32. As such, RTC, Br. 32
dismissed both cases. LBP’s MRs were also dismissed, prompting it
to file petitions for certiorari before the SC. SC ruled that RTC Br. 32
has jurisdiction over all cases of determination of just
compensation within the province of Negros Oriental, regardless of
WoN the properties are outside its regular jurisdiction.
DOCTRINE: By “special” jurisdiction, SACs exercise power in
addition to or over and above the ordinary jurisdiction of the RTC,
such as taking cognizance of suits involving agricultural lands
located outside their regular territorial jurisdiction, so long as they
are within the province where they sit as SACs.
FACTS:
Land Bank (LBP) filed cases for determination of just compensation against Corazon Villegas, and heirs of Catalino Noel and Procula Sy before
the RTC of Dumaguete City Br.32, sitting as a Special Agrarian Court (SAC) for the province of Negros Oriental. Villegas’ property was in
Guihulngan City, while the heirs’ land was in Bayawan City, both in Negros Oriental, but which were outside the regular territorial jurisdiction of
RTC Br. 32 of Dumaguete City.
RTC Br. 32 dismissed both cases for lack of jurisdiction, ruling that, although it was designated as the SAC for Negros Oriental, such
designation did not expand its territorial jurisdiction to hear agrarian cases, which are within the territorial jurisdiction of Guihulngan City and
Bayawan City.
LBP moved for reconsideration of the 2 cases but Br. 32 dismissed the motions. LBP directly filed petitions for certiorari before the SC, raising
purely a question of law.
RESPONDENT’S ARGUMENT(S): RTC, Br. 32 based its order on Deputy Court Administrator Zenaida Elepaño’s opinion that single sala courts
have jurisdiction over agrarian cases involving lands located within its territorial jurisdiction. Furthermore, the RTC’s designation as a SAC did
not expand its territorial jurisdiction. The jurisdiction of such SAC over agrarian cases is co-extensive with its territorial jurisdiction. While it has
been designated as SAC for the Province of Negros Oriental, its jurisdiction as an RTC did not cover the whole province. As for the heirs of Noel,
LBP had already paid them for their land.
ISSUE(S): WoN an RTC, acting as Special Agrarian Court, has jurisdiction over just compensation cases involving agricultural
lands located outside its regular jurisdiction but within the province where it is designated as an agrarian court under the
Comprehensive Agrarian Reform Law of 1998 —Y
Maite Fernandez Page 1 of 2 Case # 13
HELD:
Jurisdiction is the court’s authority to hear and determine a case. Such jurisdiction over the nature and subject matter of an action is conferred
by law.
In the case at bar, Secs. 56 and 57 of the CARL of 1998 provide that a branch of an RTC designated as SAC for a province has original and
exclusive jurisdiction over all petitions for the determination of just compensation and prosecution of all criminal offenses under CARL in that
province (Republic v. CA).
By “special” jurisdiction, SACs exercise power in addition to or over and above the ordinary jurisdiction of the RTC, such as taking cognizance
of suits involving agricultural lands located outside their regular territorial jurisdiction, so long as they are within the province where they sit as
SACs.
CARL requires the designation of the SC before an RTC branch can function as a SAC. Br. 64 of Guihulngan City and Br. 63 of Bayawan City
have not been designated as SAC by the SC. Consequently, they cannot hear just compensation just because the lands subject of such cases
happen to be within their territorial jurisdiction. Since RTC Br. 32 of Dumaguete City is the designated SAC for Negros Oriental, it has
jurisdiction over all cases of determination of just compensation involving agricultural lands within that province, regardless of WoN those
properties are outside its regular territorial jurisdiction.
SC GRANTS the petitions and SETS ASIDE the orders of RTC Br. 32 of Dumaguete City. The Court DIRECTS said RTC to immediately hear and
decide the 2 cases unless a compromise agreement has been approved.
NOTE: The scra states that it’s a Special Civil Action for certiorari (R65), but it was mentioned in the body that the petition for
certiorari was directly filed with the SC since it raised only questions of law (R45).
Maite Fernandez Page 2 of 2 Case # 13

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LAND BANK OF THE PHILIPPINES v. GR No.

Maite Fernandez Page 2 of 2 Case # 13

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