G.R. No. 192396 , January 17, 2018
STEPHEN A. ANTIG, as representative of AMS BANANA EXPORTER, INC., BERNARDITA S. LEMOSNERO, JEMARIE J. TESTADO, THOMAS BERNARD C. ALLADIN, and GERARDO ARANGOSO, Petitioners, vs. ANASTACIO ANTIPUESTO, in his own capacity and as representative of AMS KAPALONG AGRARIAN REFORM BENEFICIARIES MULTIPURPOSE COOPERATIVE (AMSKARBEMCO) and its members, Respondents.

FACTS

Petitioners are landowners who voluntarily offered their agricultural lands under the CARP’s Voluntary Offer to Sell scheme. Their lessee, AMS Banana Exporter, Inc., had standing crops and improvements on the leased portions. The Land Bank of the Philippines (LBP) valued the lands, but petitioners protested before the DAR Adjudication Board (DARAB), arguing the valuation excluded the value of the standing crops and improvements owned by AMS. While this administrative protest was pending, Certificates of Land Ownership Award were issued to respondent agrarian reform beneficiaries.
The Provincial Agrarian Reform Officer notified AMS of an impending physical takeover of the lands by the beneficiaries. Consequently, petitioners filed a Petition for Injunction before the Regional Trial Court designated as a Special Agrarian Court (SAC), seeking to enjoin the Department of Agrarian Reform from installing the beneficiaries. The SAC issued the injunction. The Court of Appeals reversed the SAC’s orders, ruling it acted with grave abuse of discretion.

ISSUE

Whether the Special Agrarian Court properly assumed jurisdiction and issued an injunction to halt the installation of agrarian reform beneficiaries pending the DARAB’s administrative determination of just compensation that includes the value of standing crops and improvements.

RULING

No. The Supreme Court affirmed the Court of Appeals and held the SAC committed grave abuse of discretion. The legal logic is grounded in the doctrine of primary jurisdiction and the specific statutory jurisdiction of the SAC. Under Section 50 of Republic Act No. 6657 , the DAR has primary jurisdiction to determine and adjudicate agrarian reform matters, including the administrative determination of just compensation. The SAC’s original and exclusive jurisdiction under Section 57 is triggered only over a petition for determination of just compensation, which is a judicial function. Here, the petitioners’ core grievance was the alleged incomplete valuation by the LBP, a matter squarely within the DARAB’s ongoing administrative proceedings. By issuing an injunction based on this pending administrative issue, the SAC improperly interfered with the DAR’s exercise of its primary jurisdiction. The injunction effectively restrained the implementation of the agrarian reform program based on a dispute that was not yet ripe for judicial determination by the SAC. The proper recourse for petitioners was to await the final outcome of the DARAB proceedings and, if dissatisfied, to elevate the matter of just compensation to the SAC via the proper judicial petition, not to seek injunctive relief to stop the installation process itself.