GR 113220; (January, 1997) (Digest)
G.R. No. 113220 -21. January 21, 1997.
Department of Agrarian Reform Adjudication Board (DARAB) and Provincial Agrarian Reform Adjudicator Fe Arche-Manalang, petitioners, vs. Court of Appeals, BSB Construction and Agricultural Development Corporation, and Carol Baucan, respondents.
FACTS
Two groups of individuals separately filed complaints against BSB Construction, alleging they were tenant-farmers on a 45-hectare land in Antipolo, Rizal, which the corporation sought to develop. The first group (Abogne, et al.) filed a case with the Provincial Agrarian Reform Adjudicator (PARAD), who issued a cease and desist order. BSB Construction then filed a petition with the Department of Agrarian Reform Adjudication Board (DARAB) seeking to nullify the PARAD’s order. While that petition was pending, a second group (Bea, et al.) filed a similar complaint directly with the DARAB, which then issued its own status quo order and later a warrant of arrest against BSB Construction’s president for alleged violation of that order.
BSB Construction challenged the jurisdiction of both the PARAD and the DARAB before the Court of Appeals via certiorari. The Court of Appeals ruled that the PARAD had jurisdiction to issue the initial restraining order but annulled the DARAB’s status quo order and warrant of arrest, holding that the DARAB acted without jurisdiction. The DARAB and the PARAD filed the instant petition, assailing only the portion of the decision that nullified the DARAB’s orders.
ISSUE
Whether the DARAB had jurisdiction to take cognizance of the complaint filed by the second group (Bea, et al.) in the first instance and to issue the consequent status quo order and warrant of arrest.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The DARAB did not have original jurisdiction over the complaint filed by the second group. Under the DARAB’s own Revised Rules of Procedure and the Comprehensive Agrarian Reform Law ( R.A. No. 6657 ), the PARAD has exclusive original jurisdiction over agrarian cases within its territorial area. The DARAB’s jurisdiction is primarily appellate.
The legal logic is clear on jurisdictional hierarchy. The complaint by the Bea group involved the same land and substantially the same issues as the pending case before the PARAD. The DARAB’s rules mandated that such a complaint should have been endorsed to the PARAD for consolidation or treated as an intervention. By taking original cognizance of the case, the DARAB violated its procedural rules and acted without jurisdiction. Its issuance of the status quo order and a warrant of arrest, based on this improperly assumed original jurisdiction, was therefore void. The Court emphasized that an adjudicative body must follow its own rules and cannot exercise unfettered discretion to suspend them, as doing so would create instability and disorder in legal procedure.