GR 154112; (September, 2004) (Digest)
G.R. No. 154112; September 23, 2004
DEPARTMENT OF AGRARIAN REFORM, petitioner, vs. ROBERTO J. CUENCA and Hon. ALFONSO B. COMBONG JR., in His Capacity as the Presiding Judge of the Regional Trial Court, Branch 63, La Carlota City, respondents.
FACTS
Respondent Roberto Cuenca, owner of an 81-hectare sugar land, received a Notice of Coverage from the DAR placing his land under the Comprehensive Agrarian Reform Program (CARP). In response, Cuenca filed a complaint with the Regional Trial Court (RTC) of La Carlota City seeking the annulment of the Notice and a declaration of unconstitutionality of Executive Order No. 405, which designates the Land Bank for land valuation. He argued the CARP implementation period had lapsed, the coverage lacked required committee approvals, and EO 405 was an invalid presidential law-making. The RTC denied the DAR’s motion to dismiss and issued a writ of preliminary injunction, halting the CARP proceedings.
The DAR filed a petition for certiorari with the Court of Appeals, asserting that the RTC had no jurisdiction to issue the injunction under Sections 55 and 68 of RA 6657 (CARP Law), which prohibit courts from issuing injunctions against the DAR in agrarian reform implementation. The CA dismissed the DAR’s petition, ruling that since Cuenca’s complaint raised pure questions of law, including constitutional issues, the RTC had jurisdiction over its subject matter.
ISSUE
Whether the Regional Trial Court had jurisdiction to entertain the complaint and issue a writ of preliminary injunction against the implementation of the DAR’s Notice of Coverage.
RULING
No. The Supreme Court reversed the Court of Appeals and nullified the RTC’s orders. The Court held that jurisdiction over agrarian reform matters is vested by law in the Department of Agrarian Reform and the Department of Agrarian Reform Adjudication Board (DARAB), not the regular courts. Section 50 of RA 6657 explicitly grants the DAR primary jurisdiction to adjudicate all agrarian disputes, including the application, implementation, and enforcement of the CARP. The issues raised by Cuenca—the validity of the Notice of Coverage, the alleged lapse of the implementation period, and the constitutionality of EO 405—are all intrinsically linked to the CARP implementation process. They are, therefore, agrarian controversies falling under the DAR’s special competence.
Furthermore, Sections 55 and 68 of RA 6657 impose a clear prohibition against courts issuing restraining orders or injunctions to impede the DAR in its implementation of the program. This statutory bar is designed to prevent legal maneuvers from obstructing agrarian reform. The RTC’s assumption of jurisdiction and issuance of the injunction constituted grave abuse of discretion, as it directly contravened this explicit legislative mandate. The proper recourse for Cuenca was to exhaust administrative remedies within the DAR framework before seeking judicial review.