GR 222882; (December, 2020) (Digest)
G.R. No. 222882 , December 02, 2020
BENITO MARASIGAN, JR., PETITIONER, VS. PROVINCIAL AGRARIAN REFORM OFFICER, LAND BANK OF THE PHILIPPINES AND DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD (DARAB), RESPONDENTS.
FACTS
Petitioner Benito Marasigan, Jr. is the registered owner of two parcels of land in Batangas. Portions of these lands were compulsorily acquired under the Comprehensive Agrarian Reform Program (CARP). The Land Bank of the Philippines (LBP) valued the acquired portions, but Marasigan rejected the offered compensation. Consequently, the Department of Agrarian Reform (DAR) initiated summary administrative proceedings before the Provincial Agrarian Reform Adjudicator (PARAD) for the preliminary determination of just compensation. The PARAD upheld the LBP’s valuation. Marasigan appealed to the Department of Agrarian Reform Adjudication Board (DARAB), arguing that the land should not have been placed under CARP coverage and that the proceedings were invalid due to lack of proper identification of the acquired portion and his non-participation.
ISSUE
Whether the DARAB correctly dismissed Marasigan’s appeal for lack of jurisdiction.
RULING
Yes, the DARAB correctly dismissed the appeal. The Supreme Court affirmed the rulings of the Court of Appeals and the DARAB, holding that the PARAD’s decision in a summary administrative proceeding for the preliminary determination of just compensation is not appealable to the DARAB. The legal logic is anchored on the distinct jurisdictional regimes for agrarian reform matters. The PARAD’s function in such proceedings is merely preliminary and administrative. A landowner dissatisfied with the PARAD’s valuation has a specific statutory remedy: to file an original action for the judicial determination of just compensation with the Regional Trial Court sitting as a Special Agrarian Court (RTC-SAC) within fifteen (15) days from receipt of the PARAD’s decision. This original action is a judicial proceeding, not an appeal. The DARAB’s jurisdiction is limited to adjudicating agrarian reform implementation cases and does not extend to reviewing these preliminary administrative valuations. Since Marasigan did not file an original action with the RTC-SAC but instead erroneously appealed to the DARAB, the DARAB acted correctly in dismissing his appeal for lack of jurisdiction. His substantive challenges to the CARP coverage and the identification process, while potentially meritorious on their own, must be raised in the proper judicial forum, the RTC-SAC.