GR 152611; (August, 2003) (Digest)
G.R. No. 152611 ; August 5, 2003
LAND BANK OF THE PHILIPPINES, petitioner, vs. SEVERINO LISTANA, SR., respondent.
FACTS
Respondent Severino Listana, Sr. voluntarily offered his land for sale to the government under the Comprehensive Agrarian Reform Law (CARL). The Department of Agrarian Reform Adjudication Board (DARAB) fixed just compensation at P10,956,963.25. Petitioner Land Bank of the Philippines (LBP) failed to comply with the writ of execution for this amount. Consequently, respondent filed a Motion for Contempt with the Provincial Agrarian Reform Adjudicator (PARAD). The PARAD granted the motion and issued an order for the arrest of LBP Manager Alex A. Lorayes for indirect contempt. Simultaneously, LBP had filed a separate petition for judicial determination of just compensation with the Regional Trial Court (RTC) sitting as a Special Agrarian Court (SAC).
To prevent the arrest, LBP filed a petition for injunction with the RTC (Branch 51), which issued an order enjoining the PARAD from enforcing the arrest order. Respondent then filed a special civil action for certiorari with the Court of Appeals (CA) to nullify the RTC’s injunction. The CA granted the petition and annulled the RTC’s orders, prompting LBP to elevate the case to the Supreme Court via this petition for review.
ISSUE
The primary issue is whether the PARAD acted with jurisdiction in issuing the order for indirect contempt and arrest against LBP’s manager.
RULING
The Supreme Court granted LBP’s petition and reversed the Court of Appeals. The Court held that the PARAD’s contempt proceedings were null and void for lack of jurisdiction. While quasi-judicial bodies like the DARAB possess the power to cite persons for indirect contempt under Rule 71 of the Rules of Court, the proper procedure requires them to initiate the charge by filing a verified petition with the proper Regional Trial Court. The RTC retains the exclusive jurisdiction to hear and decide indirect contempt cases.
In this instance, the contempt charge was improperly initiated by respondent’s mere “Motion for Contempt” filed directly with the PARAD, not by a verified petition filed with the RTC. Furthermore, the PARAD itself decided the contempt charge and ordered the arrest, which was an act beyond its jurisdiction. Consequently, all proceedings stemming from the invalid motion, including the arrest order, were null and void. The Supreme Court reinstated the RTC’s injunction order, which correctly restrained the enforcement of the PARAD’s void contempt order. The ruling underscores that the power to punish for indirect contempt, being a severe power affecting liberty, is strictly construed and must be exercised only by courts of law in accordance with prescribed procedures.