G.R. No. 221484, November 19, 2018
Robustum Agricultural Corporation, Petitioner, vs. Department of Agrarian Reform and Land Bank of the Philippines, Respondents.

FACTS

Petitioner Robustum Agricultural Corporation is the registered owner of a 5-hectare agricultural land in Silay City, which was originally part of a larger estate owned by its predecessor-in-interest, Puyas Agro, Inc. In December 2013, the Department of Agrarian Reform (DAR) sent petitioner a letter transmitting a copy of a notice of coverage (NOC) for the mother estate, informing petitioner that as a transferee, it would be included as an alternative landowner and payee for compensation under the Comprehensive Agrarian Reform Program (CARP). Petitioner refused to receive this letter and the attached NOC. Subsequently, in June 2014, the DAR issued and published a new NOC in a newspaper of general circulation, covering the mother estate and petitioner’s land.
Petitioner filed a Petition for Quieting of Title and Declaratory Relief before the Regional Trial Court (RTC) of Silay City, arguing the published NOC was ineffective. It contended the DAR violated its own Administrative Order by immediately resorting to publication without first attempting personal service and by failing to post the notice on the land and in local government offices. Petitioner sought a declaration that its land was exempt from CARP coverage and an injunction against the DAR and Land Bank of the Philippines (LBP). The RTC dismissed the petition for lack of jurisdiction, ruling that the issues pertained to CARP implementation, which falls under the DAR’s exclusive quasi-judicial authority.

ISSUE

Whether the Regional Trial Court correctly dismissed the petition for lack of jurisdiction, holding that the issues raised pertain to the implementation of agrarian reform, which is within the exclusive primary jurisdiction of the Department of Agrarian Reform.

RULING

Yes, the Supreme Court affirmed the RTC’s dismissal. The Court held that the RTC correctly declined jurisdiction because the core issue involved the implementation of the agrarian reform program, a matter expressly falling under the DAR’s primary and exclusive jurisdiction pursuant to Section 50 of Republic Act No. 6657, as amended. Petitioner’s action, though framed as one for quieting of title and declaratory relief, essentially questioned the validity and proper service of the notice of coverage—a procedural step integral to the land acquisition process under CARP.
The legal logic is that jurisdiction is determined by the nature of the principal relief sought. An action for quieting of title requires the plaintiff to demonstrate both legal ownership and that the defendant’s claim is invalid. Here, the DAR’s claim over the land arises from its mandate under CARP. Therefore, to resolve whether the DAR’s claim is invalid, the court must first determine if the land is rightfully covered by agrarian reform. This threshold question—whether a property is subject to CARP coverage—is a prejudicial issue that is precisely within the DAR’s primary jurisdiction to decide. The Court emphasized that the DAR must first ascertain coverage before any judicial action questioning it can prosper. Allowing the RTC to rule on the validity of the NOC would be a premature incursion into the DAR’s exclusive domain. The alleged procedural lapses in serving the NOC are not mere ministerial errors but are intertwined with the substantive determination of coverage, which the DAR is empowered to adjudicate. Consequently, petitioner must first exhaust administrative remedies before the DAR.