GR 112526; (October, 2001) (Digest)
G.R. No. 112526; October 12, 2001
Sta. Rosa Realty Development Corporation, petitioner, vs. Court of Appeals, Juan B. Amante, et al., respondents.
FACTS
Petitioner Sta. Rosa Realty Development Corporation (SRRDC) is the registered owner of two parcels of land in Cabuyao, Laguna, with a total area of 254.6 hectares. SRRDC alleged the land is a watershed providing potable water to the Canlubang community, hosts numerous light industries, and has a terrain with slopes of 18% and above, making it unsuitable for agriculture. Private respondents, claiming to be farmers, occupied portions of the land. After SRRDC filed ejectment cases against them, the respondents petitioned the Department of Agrarian Reform (DAR) for compulsory acquisition of the property under the Comprehensive Agrarian Reform Program (CARP). The DAR issued a notice of coverage and, despite SRRDC’s formal protest, eventually issued Notices of Acquisition.
The DARAB assumed jurisdiction and ordered the compulsory acquisition, a decision affirmed by the Court of Appeals. SRRDC elevated the case to the Supreme Court, contending the DARAB had no jurisdiction as the land was non-agricultural, and the determination of just compensation for non-agricultural lands falls under the jurisdiction of the regular courts, not the DARAB.
ISSUE
Whether the DARAB properly exercised jurisdiction over the petition for compulsory acquisition and determination of just compensation for the subject properties.
RULING
The Supreme Court ruled that the DARAB did not have jurisdiction. The Court emphasized that jurisdiction is conferred by law and is determined by the allegations in the complaint and the nature of the relief sought. SRRDC consistently asserted that its land was non-agricultural, being a watershed with slopes exceeding 18% and used for industrial purposes. Under Section 57 of R.A. No. 6657 (CARP Law), the Special Agrarian Courts (Regional Trial Courts) have original and exclusive jurisdiction over all petitions for the determination of just compensation, and this jurisdiction extends to cases where the core issue involves the very eligibility of the land for CARP coverage. Since a fundamental and unresolved question existed regarding whether the land was agricultural and thus subject to CARP, the DARAB should not have proceeded with the acquisition and compensation process. The Court held that the DARAB’s jurisdiction presupposes that the land is subject to agrarian reform. Therefore, the case was remanded to the DARAB for the preliminary task of re-evaluating and determining the nature of the land to resolve the issue of its coverage. The effects of any Certificates of Land Ownership Award (CLOAs) issued were ordered stayed pending final resolution.