GR 136814; (September, 2005) (Digest)
G.R. No. 136814 September 2, 2005
Spouses Carlos Gocotano and Visitacion Gocotano and Clodualdo Gocotano, Petitioners, vs. Spouses Marcelo Gocotano and Margarita Gocotano, Respondents.
FACTS
Petitioners, the landowners, filed a complaint for determination of just compensation with the Regional Trial Court (RTC) of Cebu, sitting as a Special Agrarian Court (SAC). This action was initiated after respondents, claiming to be tenants, filed a case with the Department of Agrarian Reform Adjudication Board (DARAB) for the acquisition of the petitioners’ land under the Comprehensive Agrarian Reform Law (CARL). The DARAB rendered a judgment allowing the respondents to acquire the property for a sum of only Eleven Thousand Pesos (₱11,000.00).
Petitioners alleged that the DARAB’s valuation was grossly inadequate, asserting the land’s true value to be Two Million Pesos (₱2,000,000.00) based on prevailing market rates. They contended that the SAC had exclusive original jurisdiction over the determination of just compensation, rendering the DARAB’s valuation merely preliminary and not binding.
ISSUE
Whether the Regional Trial Court, sitting as a Special Agrarian Court, has jurisdiction over the complaint for determination of just compensation despite a prior valuation by the DARAB.
RULING
Yes. The Supreme Court affirmed the SAC’s jurisdiction. The legal logic is grounded on the explicit provisions of Republic Act No. 6657 (CARL) and its implementing rules. While the Department of Agrarian Reform (DAR) has the primary authority to initiate and process land acquisition, including an initial determination of compensation, any party dissatisfied with this administrative valuation may bring the matter directly to the SAC.
The SAC possesses exclusive and original jurisdiction over all petitions for the determination of just compensation. This jurisdiction is not appellate but original in nature. The DARAB’s decision on valuation is not final and executory; it is merely a preliminary administrative determination. The landowner’s recourse is not an appeal within the DARAB hierarchy but a judicial action before the SAC, which is mandated to conduct a trial, receive evidence, and independently ascertain the full and fair monetary equivalent of the property. Therefore, the petitioners correctly invoked the SAC’s jurisdiction to obtain a proper judicial valuation, rendering the DARAB’s “measly” award inconclusive.