GR 164631; (June, 2009) (Digest)
G.R. No. 164631; June 26, 2009
LAND BANK OF THE PHILIPPINES, Petitioner, vs. RENE RALLA BELISTA, Respondent.
FACTS
Respondent Rene Ralla Belista was the donee of agricultural lands placed under the Comprehensive Agrarian Reform Program. Dissatisfied with the valuation by the Department of Agrarian Reform (DAR) and Land Bank of the Philippines (LBP), she filed a Petition for Valuation and Payment of Just Compensation before the DARAB-Regional Adjudicator for Region V (RARAD-V) in November 2002. The RARAD-V issued a decision fixing just compensation, which it later modified in an October 2003 Order. Aggrieved by this valuation, petitioner LBP filed an original Petition for Determination of Just Compensation directly with the Regional Trial Court (RTC), sitting as a Special Agrarian Court (SAC), in October 2003.
The RTC dismissed LBP’s petition motu proprio, citing failure to exhaust administrative remedies for not appealing the RARAD-V Order to the DARAB under Sections 5, 6, and 7, Rule XIX of the 2003 DARAB Rules of Procedure. The Court of Appeals affirmed the dismissal, ruling that the 2003 DARAB Rules, effective February 2003, governed LBP’s filing in October 2003. The CA held that an appeal to the DARAB was a mandatory prerequisite before resort to the SAC.
ISSUE
Whether the RTC, acting as a Special Agrarian Court, correctly dismissed LBP’s petition for determination of just compensation for failure to exhaust administrative remedies by not appealing first to the DARAB under the 2003 DARAB Rules.
RULING
No. The Supreme Court reversed the CA and RTC, holding that the SAC had original and exclusive jurisdiction over petitions for determination of just compensation, and no prior appeal to the DARAB was required. The legal logic is anchored on Section 57 of Republic Act No. 6657 (Comprehensive Agrarian Reform Law), which explicitly vests original and exclusive jurisdiction in the RTC, sitting as a SAC, over all petitions for the determination of just compensation. Jurisdiction conferred by statute cannot be diminished by procedural rules. The Court clarified that while the 2003 DARAB Rules provided an appeal from the adjudicator to the DARAB, this internal rule could not amend the substantive jurisdictional grant under RA 6657. Direct resort to the SAC is authorized by law. The fact that the respondent’s original claim was filed in 2002 under the old DARAB rules, which deemed adjudicator decisions on valuation non-appealable to the DARAB, further supported LBP’s direct filing with the SAC. The RTC’s dismissal was therefore a grave error. The SAC was directed to hear LBP’s petition without delay.