GR 194167; (February, 2021) (Digest)
G.R. No. 194167, February 10, 2021
Land Bank of the Philippines, Petitioner, vs. Magdalena Quilit and Mauricio Laoyan, Respondents.
FACTS
On August 13, 1999, respondents Magdalena Quilit and Mauricio Laoyan filed a petition for annulment of sale and redemption of two agricultural parcels of land in La Trinidad, Benguet, formerly owned by the Spouses Tolding and acquired by petitioner Land Bank of the Philippines (LBP) through foreclosure. The Regional Agrarian Reform Adjudicator (RARAD) rendered a Decision on December 17, 1999, holding that respondents may exercise their right of redemption. LBP’s Notice of Appeal was denied by the RARAD for being filed late. The RARAD issued a Writ of Execution and later an Order directing the Register of Deeds to release LBP’s titles for cancellation and the issuance of new titles in respondents’ names. Subsequently, new titles were issued in favor of respondents. On May 4, 2000, LBP filed a Petition for Certiorari with the Department of Agrarian Reform Adjudication Board (DARAB) assailing the RARAD’s Decision and Orders. On August 7, 2006, the DARAB dismissed the petition, citing the case of Department of Agrarian Reform Adjudication Board v. Lubrica, which held that the DARAB, as a quasi-judicial body, has no jurisdiction over petitions for certiorari. LBP’s motion for reconsideration was denied. LBP then filed a Petition for Review with the Court of Appeals (CA), which was denied in its October 19, 2010 Decision, affirming the DARAB’s dismissal. Hence, this petition.
ISSUE
Whether the DARAB erred in dismissing LBP’s Petition for Certiorari for lack of jurisdiction.
RULING
The Supreme Court denied the petition and affirmed the CA Decision. The Court held that the DARAB, as a quasi-judicial body with limited jurisdiction, has no authority to entertain petitions for certiorari, as established in the doctrinal case of Department of Agrarian Reform Adjudication Board v. Lubrica. This ruling applies even to petitions filed under the DARAB’s 1994 Rules of Procedure prior to the Lubrica decision. The Court further noted that LBP failed to file the requisite motion for reconsideration with the RARAD within the five-day reglementary period provided by the DARAB rules. Moreover, LBP’s failure to timely file a petition for certiorari with the proper appellate court (the CA) within 60 days from notice of the RARAD’s Order rendered the said order final and executory. Thus, the RARAD’s December 17, 1999 Decision remains final and beyond judicial review.