GR 166461; (April, 2010) (Digest)
G.R. No. 166461 ; April 30, 2010
HEIRS OF LORENZO and CARMEN VIDAD and AGVID CONSTRUCTION CO., INC., Petitioners, vs. LAND BANK OF THE PHILIPPINES, Respondent.
FACTS
Petitioners voluntarily offered their 589.8661-hectare land in Isabela for sale under the Comprehensive Agrarian Reform Program. Respondent Land Bank of the Philippines (LBP), as the financial intermediary, initially valued the 490.3436-hectare acquired portion at ₱2,961,333.03. Petitioners rejected this and filed a petition with the Department of Agrarian Reform Adjudication Board (DARAB). After a revaluation by LBP, which petitioners also rejected, the Regional Agrarian Reform Adjudicator (RARAD) fixed just compensation at ₱32,965,408.46. Petitioners accepted this decision, while LBP moved for reconsideration, which was denied.
LBP then filed a petition for determination of just compensation with the Regional Trial Court (RTC), sitting as a Special Agrarian Court (SAC). Petitioners moved to dismiss, arguing the RARAD decision was final and executory, constituting res judicata, and that LBP lacked legal personality to file the case. The SAC denied the motion, held petitioners in default for failing to answer, and proceeded to hear LBP’s evidence ex-parte. The SAC fixed just compensation at ₱5,626,724.47. The Court of Appeals affirmed the SAC decision.
ISSUE
Whether the SAC correctly assumed jurisdiction over LBP’s petition for determination of just compensation and whether LBP has the legal personality to institute such an action.
RULING
Yes. The Supreme Court affirmed the CA and SAC decisions. The Court held that under Section 57 of Republic Act No. 6657 , the SAC (the RTC) has original and exclusive jurisdiction over all petitions for the determination of just compensation. This jurisdiction cannot be shared concurrently with the DARAB or its adjudicators. The RARAD’s decision, therefore, was rendered without jurisdiction and is consequently void. A void judgment can never become final and executory and cannot constitute res judicata.
Furthermore, the Court ruled that LBP has the legal personality to institute the petition before the SAC. As the financial intermediary of the agrarian reform program, LBP is statutorily tasked with determining land valuation and compensating landowners. When a landowner rejects LBP’s valuation, it is imperative for LBP to seek a judicial determination of just compensation to ascertain the exact amount it is obligated to pay. This right to file an action is a necessary consequence of its mandate and is essential for the proper implementation of the agrarian reform program. The SAC correctly exercised its exclusive jurisdiction in determining the final valuation based on the evidence presented.