GR 106028; (April, 2001) (Digest)
G.R. No. 106028 May 9, 2001
LILIA Y. GONZALES, petitioner, vs. COURT OF APPEALS, HON. ANTONIO S. MARAYA, as Regional Director, DAR, Region VI, Iloilo City, LAND BANK OF THE PHILIPPINES, Iloilo City, RAMON PERUEL, MARCELINO BOLIVAR, ALFONSO CARMELO, ESPERIDION PELEGRINO and WILFREDO CARMELO, respondents.
FACTS
Petitioner Lilia Y. Gonzales received two Orders from the DAR Regional Director directing her to surrender her land titles and for the Land Bank to pay her compensation under the Operation Land Transfer program of P.D. No. 27. Gonzales filed a Petition for Certiorari and Prohibition with the Court of Appeals to annul these orders, alleging lack of jurisdiction and denial of due process. She claimed she never filed a land transfer claim, was not notified of the survey and valuation, and that P.D. No. 27 had been repealed by R.A. No. 6657. The Court of Appeals dismissed the petition for failure to exhaust administrative remedies, ruling that certiorari cannot substitute for an appeal.
ISSUE
Whether the Court of Appeals erred in dismissing the petition for failure to exhaust administrative remedies and in not finding that the DAR Regional Director acted without or in excess of jurisdiction.
RULING
The Supreme Court denied the petition, affirming the Court of Appeals. The doctrine of exhaustion of administrative remedies is applicable. The assailed orders were issued by the DAR Regional Director in the performance of his quasi-judicial functions. The law provides adequate administrative remedies, such as a motion for reconsideration before the DAR Regional Director or an appeal to the Department of Agrarian Reform Adjudication Board (DARAB). The DARAB has primary and exclusive original jurisdiction over agrarian reform matters, including the determination of just compensation for lands acquired under P.D. No. 27 and R.A. No. 6657. The petitioner’s premature resort to judicial action is fatal. The Court found no merit in the claim of denial of due process, as records indicated notices were sent, and the claim that P.D. No. 27 was repealed is incorrect, as R.A. No. 6657 recognizes its continued application for lands already covered. The Regional Director did not act with grave abuse of discretion; thus, neither certiorari nor prohibition lies. The rule on exhaustion ensures administrative agencies resolve matters within their specialized competence, promoting efficiency and respecting the hierarchy of remedies.