CASE of PHILIPPINE VETERANS BANK V. CA

PHILIPPINE VETERANS BANK,
petitioner, COURT’S RULING:

vs.
THE HON. COURT OF APPEALS, HON. SECRETARY OF THE DEPT. OF AGRARIAN REFORM, There is nothing contradictory between the provision of §50 granting the DAR primary
DEPT. OF AGRARIAN REFORM ADJUDICATION BOARD, DAVAO CITY and LAND BANK OF jurisdiction to determine and adjudicate "agrarian reform matters" and exclusive original
THE PHILIPPINES,respondents. jurisdiction over "all matters involving the implementation of agrarian reform," which
includes the determination of questions of just compensation, and the provision of §57
PONENTE: JUSTICE MENDOZA granting Regional Trial Courts "original and exclusive jurisdiction" over (1) all petitions for
the determination of just compensation to landowner, and (2) prosecutions of criminal
PROMULGATED: January 18, 2000 offenses under R.A. No. 6657.4The first refers to administrative proceedings, while the
second refers to judicial proceedings. Under R.A. No. 6657, the Land Bank of the
NATURE OF THE CASE: This is a petition for review of the decision of the Court of Philippines is charged with the preliminary determination of the value of lands placed
Appeals,1 dated August 28, 1997, affirming the dismissal by the Regional Trial Court, under land reform program and the compensation to be paid for their taking. It initiates
Branch 2, Tagum, Davao, of the petition for judicial determination of the just the acquisition of agricultural lands by notifying the landowner of the government's
compensation filed by petitioner for the taking of its property under the Comprehensive intention to acquire his land and the valuation of the same as determined by the Land
Agrarian Reform Program. Bank.5 Within 30 days from receipt of notice, the landowner shall inform the DAR of his
acceptance or rejection of the offer.6 In the event the landowner rejects the offer, a
summary administrative proceeding is held by the provincial (PARAD), the regional
FACTS OF THE CASE:
(RARAD) or the central (DARAB) adjudicator, as the case may be, depending on the value
of the land, for the purpose of determining the compensation for the land. The
Petitioner Philippine Veterans Bank owned four parcels of land in Tagum, Davao, which
landowner, the Land Bank, and other interested parties are then required to submit
are covered by Transfer Certificates of Title Nos. T-38666, T-38667, T-6236, and T-27591.
evidence as to the just compensation for the land. The DAR adjudicator decides the case
The lands were taken by the Department of Agrarian Reform for distribution to landless within 30 days after it is submitted for decision.7 If the landowner finds the price
farmers pursuant to the Comprehensive Agrarian Reform Law (R.A. No. 6657). Dissatisfied unsatisfactory, he may bring the matter directly to the appropriate Regional Trial Court.8
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 To implement the provisions of R.A. No. 6657, particularly §50 thereof, Rule XIII, §11 of
a determination of the just compensation for its property. The petition was filed on the DARAB Rules of Procedure provides:
January 26, 1994 with the Regional Trial Court, Branch 2, Tagum, Davao, which on
February 23, 1995, dismissed the petition on the ground that it was filed beyond the 15- Land Valuation Determination and Payment of Just Compensation. — The
decision of the Adjudicator on land valuation and preliminary determination and
day reglementary period for filing appeals from the orders of the DARAB.
payment of just compensation shall not be appealable to the Board but shall be
brought directly to the Regional Trial Courts designated as Special Agrarian
On appeal to the Court of Appeals, the decision was affirmed.
Courts within fifteen (15) days from receipt of the notice thereof. Any party shall
Petitioner filed a motion for reconsideration, but its motion was likewise denied. be entitled to only one motion for reconsideration.
ISSUE: Wether the DAR or the RTC has jurisdiction Citing Republic v. Court of Appeals,9 this rule is an acknowledgment by the DARAB that the
power to decide just compensation cases for the taking of lands under R.A. No. 6657 is
PETITIONER’S ARGUMENT ON THE ISSUE: Phil. Veterans Bank contended that DAR vested in the courts. It is error to think that, because of Rule XIII, §11, the original and
adjudicators had no jurisdiction to determine the just compensation for the taking of exclusive jurisdiction given to the courts to decide petitions for determination of just
compensation has thereby been transformed into an appellate jurisdiction. It only means
lands under the Comprehensive Agrarian Reform Program because such jurisdiction is
that, in accordance with settled principles of administrative law, primary jurisdiction is
vested in the Regional Trial Courts. vested in the DAR as an administrative agency to determine in a preliminary manner the
reasonable compensation to be paid for the lands taken under the Comprehensive
Agrarian Reform Program, but such determination is subject to challenge in the courts.
The jurisdiction of the Regional Trial Courts is not any less "original and exclusive" because
the question is first passed upon by the DAR, as the judicial proceedings are not a
continuation of the administrative determination. For that matter, the law may provide
that the decision of the DAR is final and unappealable. Nevertheless, resort to the courts
cannot be foreclosed on the theory that courts are the guarantors of the legality of
administrative action.10

CASE of PHILIPPINE VETERANS BANK V. CA

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CASE of PHILIPPINE VETERANS BANK V. CA

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PHILIPPINE VETERANS BANK,

petitioner, COURT’S RULING:

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