GR 142628; (February, 2007) (Digest)
G.R. No. 142628. February 6, 2007.
SPRINGFIELD DEVELOPMENT CORPORATION, INC. and HEIRS OF PETRA CAPISTRANO PIIT, Petitioners, vs. HON. PRESIDING JUDGE OF RTC OF MISAMIS ORIENTAL, BRANCH 40, DARAB, DAR REGION X DIRECTOR, ROSALIO GAMULO, et al., Respondents.
FACTS
Petitioners Springfield Development Corporation and the Heirs of Petra Piit owned land in Cagayan de Oro City. The Department of Agrarian Reform (DAR) issued a Notice of Coverage over the property under the Comprehensive Agrarian Reform Law. In DARAB Case No. X-305, the Provincial Adjudicator declared the land residential and unsuitable for agriculture. This 1991 decision became final and executory. Petitioners subsequently developed the land into a subdivision.
Years later, the DAR Regional Director filed a petition for relief from judgment. In 1995, the DARAB granted the petition, set aside its prior final decision, and gave due course to the Notice of Coverage. It later ordered petitioners to pay farmer-beneficiaries for the land’s value. Claiming the 1995 DARAB decision was rendered without notice and hearing, petitioners filed a petition for annulment of judgment with the Regional Trial Court (RTC). The RTC dismissed the case for lack of jurisdiction.
ISSUE
Whether the Regional Trial Court has jurisdiction to annul a final judgment of the Department of Agrarian Reform Adjudication Board.
RULING
No, the RTC has no jurisdiction. The Supreme Court affirmed the dismissal, holding that the RTC cannot annul a judgment of the DARAB, a quasi-judicial agency which is a co-equal body. The doctrine of judicial stability or non-interference dictates that courts of equal and coordinate jurisdiction cannot interfere with each other’s judgments. This principle extends to quasi-judicial bodies like the DARAB when they are performing adjudicatory functions.
The proper remedy for an aggrieved party from a final DARAB decision is to file a petition for review with the Court of Appeals under Rule 43 of the Rules of Court. This rule provides a uniform procedure for appeals from various quasi-judicial agencies, including the DARAB. The Court emphasized that the hierarchy of judicial review is designed to promote orderly procedure. Allowing an RTC to annul a DARAB decision would disrupt this hierarchy and undermine the doctrine of finality of judgments. Petitioners’ claim of a void judgment due to lack of due process does not confer jurisdiction on the RTC; such an allegation is a matter to be raised in the proper appellate review by the Court of Appeals.