G.R. No. 158464, August 02, 2016
JOCELYN S. LIMKAICHONG, PETITIONER, VS. LAND BANK OF THE PHILIPPINES, DEPARTMENT OF AGRARIAN REFORM, REPRESENTED BY THE SECRETARY OF AGRARIAN REFORM, THROUGH THE PROVINCIAL AGRARIAN REFORM OFFICER, RESPONDENTS.

FACTS

The case involves a petition for the determination of just compensation filed by landowner Jocelyn S. Limkaichong. The Department of Agrarian Reform (DAR) initiated the acquisition of her land under the Comprehensive Agrarian Reform Program. After administrative proceedings, Limkaichong received the DAR’s valuation but disagreed with the amount. She subsequently filed a petition for judicial determination of just compensation with the Regional Trial Court (RTC) acting as a Special Agrarian Court (SAC) approximately two and a half months after receiving the DAR’s decision.
The respondents, Land Bank of the Philippines and the DAR, moved for the dismissal of Limkaichong’s petition. They argued that her filing was made beyond the mandatory 15-day reglementary period prescribed under Section 11, Rule XIII of the 1994 DARAB Rules of Procedure, which was later replicated in Section 6, Rule XIX of the 2009 DARAB Rules. This rule requires that a party disagreeing with the DAR’s valuation must file an original action with the SAC within fifteen (15) days from receipt of the administrative decision.

ISSUE

Whether the 15-day reglementary period for filing a petition for judicial determination of just compensation with the Special Agrarian Court, as imposed by the DARAB Rules of Procedure, is valid and binding.

RULING

The Supreme Court, through the separate concurring opinion of Justice Velasco, Jr., declared the 15-day filing period under the DARAB Rules null and void. The ruling is anchored on the principle that the determination of just compensation is a judicial function, a power exclusively vested in the courts and cannot be restricted by executive or administrative rule-making.
The legal logic proceeds from the constitutional guarantee that private property shall not be taken for public use without just compensation. The Court, citing the landmark case of Export Processing Zone Authority v. Dulay, has consistently held that the ascertainment of just compensation is inherently a judicial prerogative. While the DAR may conduct preliminary administrative proceedings to determine compensation, any party’s disagreement with this valuation elevates the matter to the courts for final determination. Section 57 of Republic Act No. 6657 (CARL) designates the RTCs as SACs with “original and exclusive jurisdiction” over all petitions for the determination of just compensation. This grant of jurisdiction is plenary and is not qualified or limited by any statutory prescriptive period. Therefore, any administrative rule, such as the DARAB’s 15-day period, that imposes a restrictive deadline for invoking this judicial jurisdiction constitutes a gross breach of the CARL. It effectively impedes the landowner’s right to seek judicial redress and allows an administrative body to curtail a power constitutionally entrusted to the judiciary. The period is an invalid encroachment on judicial authority and cannot bar a landowner from accessing the courts to assert their constitutional right to just compensation.