G.R. No. 173386, G.R. No. 174162, G.R. No. 183191 February 11, 2014
DEPARTMENT OF AGRARIAN REFORM, now represented by OIC-SEC. NASSER PANGANDAMAN, Petitioner, vs. TRINIDAD VALLEY REALTY & DEVELOPMENT CORPORATION, FRANNIE GREENMEADOWS PASTURES, INC., ISABEL GREENLAND AGRI-BASED RESOURCES, INC., ISABEL GREENMEADOWS QUALITY PRODUCTS, INC., ERNESTO BARICUATRO, CLAUDIO VILLO and EFREN NUEVO, Respondents.

GRACE B. FUA, in her capacity as the PROVINCIAL AGRARIAN REFORM OFFICER OF NEGROS ORIENTAL, JOSELIDO S. DAYOHA, JESUS S. DAYOHA and RODRIGO S. LICANDA, Petitioners, vs. TRINIDAD VALLEY REALTY AND DEVELOPMENT CORPORATION, FRANNIE GREENMEADOWS PASTURES, INC., ISABEL GREENLAND AGRI-BASED RESOURCES, INC., ISABEL EVERGREEN PLANTATIONS INC., MICHELLE FARMS, INC. ISABEL GREENMEADOWS QUALITY PRODUCTS, INC., ERNESTO BARICUATRO, CLAUDIO VILLO and EFREN NUEVO, Respondents.
TRINIDAD VALLEY REALTY & DEVELOPMENT CORPORATION, FRANNIE GREENMEADOWS PASTURES, INC., ISABEL GREENLAND AGRI-BASED RESOURCES, INC., ISABEL GREENMEADOWS QUALITY PRODUCTS, INC., ERNESTO BARICUATRO,CLAUDIO VILLO and EFREN NUEVO, Petitioners, vs. THE REPUBLIC OF THE PHILIPPINES and THE LAND REGISTRATION AUTHORITY, Respondents.

FACTS

Trinidad Valley Realty and Development Corporation, et al. are the registered owners of a 641.7895-hectare land in Vallehermoso, Negros Oriental, about 200 hectares of which are devoted to sugar cane. The Department of Agrarian Reform (DAR) placed 479.8905 hectares under the coverage of the Comprehensive Agrarian Reform Law (RA 6657) between March 1995 and July 2000, and subsequently issued Certificates of Land Ownership Award (CLOAs) and Transfer Certificates of Title (TCTs) to agrarian reform beneficiaries.
On June 10, 2004, Trinidad Valley Realty and Development Corporation, et al. filed a “Petition for Declaration of Unconstitutionality Through Certiorari, Prohibition and Mandamus with Prayer for Preliminary Prohibitory Injunction and Restraining Order” before the Regional Trial Court (RTC), Branch 64, Guihulngan, Negros Oriental, docketed as Special Civil Action No. 04-02-V. They alleged that the DAR committed grave abuse of discretion by: (1) passing Administrative Order No. 12, Series of 1989 and related issuances allowing it to unilaterally choose beneficiaries other than those intended by the Constitution; (2) subjecting their properties to compulsory acquisition and ordering the Land Bank to determine valuation without a judicial pronouncement on just compensation; and (3) unilaterally ordering the cancellation of their title without court intervention by issuing final CLOAs. They also contended that the Land Bank’s valuation was not just compensation and that the Register of Deeds cannot cancel their title without a court order.
The DAR filed an Answer asserting that jurisdiction over all agrarian reform matters is exclusively vested in the DAR; the power to cancel CLOAs is vested in the DAR Adjudication Board (DARAB); the RTC’s jurisdiction in agrarian matters is limited to determining just compensation and prosecuting criminal offenses under RA 6657; and the RTC has no jurisdiction over petitions for certiorari, prohibition, and mandamus in agrarian reform cases, which is vested by Section 54 of RA 6657 in the Court of Appeals (CA).
Trinidad Valley Realty and Development Corporation, et al. then filed a Motion for Leave to Amend Petition to change the action from a special civil action to an ordinary action for annulment of land titles. The RTC, in an Order dated October 26, 2004, admitted the amended petition and ruled it had jurisdiction. The DAR and LRA filed motions for reconsideration, which were denied by the RTC in an Order dated January 7, 2005.
The Republic, represented by the Solicitor General, and the LRA filed a petition for certiorari with the CA seeking to annul the RTC Order. The CA, in a Decision dated June 28, 2007, granted the petition, annulled the RTC Order, and directed the dismissal of Civil Action No. 04-02-V for lack of jurisdiction. The CA ruled that under Section 54 of RA 6657, it is the CA, not the RTC, that has jurisdiction over the case. It also cited the landmark case of Association of Small Landowners in the Phils., Inc. v. Hon. Secretary of Agrarian Reform, which declared RA 6657 constitutional, foreclosing any attack on its constitutionality. The CA further held that since the RTC lacked jurisdiction over the original petition, it had no authority to admit the amended complaint to acquire jurisdiction. The CA denied the motion for reconsideration.

ISSUE

Whether the Regional Trial Court has jurisdiction over a case involving the implementation of the Comprehensive Agrarian Reform Law (RA 6657) that assails the constitutionality of administrative orders and related issuances, and seeks remedies of certiorari, prohibition, and mandamus.

RULING

No. The Supreme Court denied the petitions and affirmed the Decision of the Court of Appeals. The RTC has no jurisdiction over the subject matter of the case.
The Court held that jurisdiction over the subject matter is conferred by law. Section 54 of RA 6657 explicitly provides that the Court of Appeals shall have the exclusive original jurisdiction over all petitions for the determination of just compensation to landowners and the prosecution of all criminal offenses under the Act. The CA shall also have exclusive appellate jurisdiction over all cases involving the constitutionality, interpretation, or implementation of RA 6657, other agrarian laws, and rules, regulations, issuances, and orders promulgated pursuant thereto.
The original petition filed by Trinidad Valley Realty and Development Corporation, et al. before the RTC was a “Petition for Declaration of Unconstitutionality Through Certiorari, Prohibition and Mandamus,” which squarely assailed the constitutionality and implementation of DAR Administrative Order No. 12, Series of 1989 and related issuances. This fell within the exclusive appellate jurisdiction of the CA under Section 54 of RA 6657. The RTC, therefore, lacked jurisdiction from the outset.
The attempt to amend the petition to an ordinary action for annulment of titles did not cure the jurisdictional defect. A court lacking jurisdiction over the subject matter has no authority to act on the case, including admitting amended pleadings. The nature of the action remained anchored on challenging the DAR’s acts in implementing RA 6657, which is within the CA’s jurisdiction.
Furthermore, the Court reiterated that the constitutionality of RA 6657 has been settled in Association of Small Landowners in the Phils., Inc. v. Hon. Secretary of Agrarian Reform. Any challenge to the constitutionality of its implementing rules and regulations must be raised in the proper forum—the Court of Appeals—as prescribed by the law itself.
Consequently, the RTC Orders dated October 26, 2004 and January 7, 2005 were null and void for having been issued without jurisdiction. The Court of Appeals correctly annulled these orders and directed the dismissal of the case.