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). The complaint stemmed from a prior DARAB case where the respondents, claiming to be tenants, were allowed to acquire the subject agricultural land under the Comprehensive Agrarian Reform Program for only ₱11,000. Petitioners alleged the land’s true value was ₱2,000,000 based on prevailing market rates.
Respondents moved to dismiss the SAC complaint, arguing the petitioners failed to exhaust administrative remedies by not appealing the DARAB decision to the Court of Appeals. The RTC denied the motion to dismiss. Respondents then filed a petition for certiorari with the Court of Appeals, which granted it and dismissed the SAC case, holding that the RTC acted without jurisdiction due to the petitioners’ failure to appeal the DARAB ruling.
ISSUE
Whether the Regional Trial Court, sitting as a Special Agrarian Court, has original and exclusive jurisdiction over a complaint for the determination of just compensation filed directly before it, notwithstanding a prior DARAB decision on land valuation.
RULING
Yes. The Supreme Court reversed the Court of Appeals and reinstated the complaint before the RTC-SAC. The legal logic is anchored on the explicit jurisdictional grant under Section 57 of Republic Act No. 6657 (CARP). This provision vests original and exclusive jurisdiction in the Special Agrarian Courts over all petitions for the determination of just compensation to landowners. This jurisdiction is not appellate but original.
The doctrine of exhaustion of administrative remedies does not apply because the quasi-judicial functions of the DARAB in land valuation are merely preliminary. The SAC is not an appellate reviewer of DARAB decisions on compensation. Once a party files a petition for just compensation directly with the SAC, the court is mandated to assume jurisdiction, conduct its own independent proceedings, and determine the proper compensation based on established legal criteria, effectively disregarding any prior administrative valuation. Therefore, the petitioners’ direct filing with the RTC-SAC was proper, and the RTC correctly denied the motion to dismiss for lack of jurisdiction.