GR 132767; (January, 2000) (Digest)
G.R. No. 132767 January 18, 2000
PHILIPPINE VETERANS BANK, petitioner, vs. THE HON. COURT OF APPEALS, HON. SECRETARY OF THE DEPT. OF AGRARIAN REFORM, DEPT. OF AGRARIAN REFORM ADJUDICATION BOARD, DAVAO CITY and LAND BANK OF THE PHILIPPINES, respondents.
FACTS
Petitioner Philippine Veterans Bank owned four parcels of land in Tagum, Davao, which were taken by the Department of Agrarian Reform (DAR) for distribution under the Comprehensive Agrarian Reform Program (CARP). Dissatisfied with the valuation made by the Land Bank of the Philippines and the DAR Adjudication Board (DARAB), the petitioner filed a petition for judicial determination of just compensation with the Regional Trial Court (RTC) of Tagum, Davao, on January 26, 1994. The RTC dismissed the petition, ruling it was filed beyond the 15-day reglementary period for appealing the DARAB’s order as provided under Section 51 of R.A. No. 6657 (CARP Law). The Court of Appeals affirmed this dismissal, citing Rule XIII, Section 11 of the DARAB Rules of Procedure, which mandates that a challenge to a DAR adjudicator’s decision on land valuation must be brought directly to the RTC, sitting as a Special Agrarian Court, within fifteen (15) days from receipt of notice.
ISSUE
Whether a petition for judicial fixing of just compensation before a Special Agrarian Court must be filed within the 15-day period provided in the DARAB Rules of Procedure.
RULING
Yes. The Supreme Court affirmed the decisions of the lower courts, holding that the petition was correctly dismissed for being filed out of time. The Court clarified the jurisdictional interplay between the DAR and the Special Agrarian Courts. While Section 57 of R.A. No. 6657 vests original and exclusive jurisdiction over petitions for determination of just compensation in the Special Agrarian Courts, the DAR is vested with primary jurisdiction under Section 50 to make a preliminary administrative determination. Rule XIII, Section 11 of the DARAB Rules implements this scheme by providing that a landowner dissatisfied with the DAR adjudicator’s valuation must bring the matter directly to the Special Agrarian Court within fifteen (15) days from receipt of the notice. This rule does not convert the court’s original jurisdiction into an appellate one; it merely recognizes the principle of primary jurisdiction, where the administrative agency makes an initial determination subject to judicial review. The 15-day period is mandatory. Since the petitioner failed to file its petition within this period without providing the date of its receipt of the DAR order to prove timeliness, the DARAB’s decision became final, and the RTC correctly dismissed the case for lack of jurisdiction.