GR 80719; (September, 1989) (Digest)
G.R. No. 80719 September 26, 1989
HILDA RALLA ALMINE, petitioner, vs. HONORABLE COURT OF APPEALS, MINISTRY OF AGRARIAN REFORM (MAR) AND SULPICIO BOMBALES, respondents.
FACTS
Petitioner Hilda Ralla Almine filed an application for retention of her riceland from the Operation Land Transfer Program with the Ministry of Agrarian Reform (MAR). After investigations, MAR officials recommended the cancellation of the Certificate of Land Transfer (CLT) issued to her tenant, respondent Sulpicio Bombales, finding her property not covered by the program. However, the Minister of Agrarian Reform ultimately denied her application for retention. Almine appealed this denial to the then Intermediate Appellate Court.
The Court of Appeals dismissed the appeal for lack of jurisdiction. It ruled that questions regarding a landowner’s right of retention, once decided by the Minister of Agrarian Reform, were appealable only to the Court of Agrarian Relations (now the Regional Trial Courts under B.P. Blg. 129). Almine filed a motion for reconsideration, arguing that the appellate court had jurisdiction under B.P. Blg. 129 over decisions of quasi-judicial agencies, and alternatively, that her petition should have been certified to the proper court. The motion was denied, prompting this petition.
ISSUE
Whether the Court of Appeals correctly dismissed the petition for review of the MAR Minister’s decision for lack of jurisdiction.
RULING
No, the Court of Appeals erred in dismissing the petition. The Supreme Court clarified the proper jurisdiction and remedy. Under Section 12 of P.D. No. 946, matters involving the administrative implementation of land transfer, including the right of retention of the landowner, are exclusively cognizable by the Secretary (then Minister) of Agrarian Reform. The law explicitly states that the decision of the Secretary may be appealed to the President of the Philippines. Consequently, such decisions are excluded from the original and exclusive jurisdiction of the then Courts of Agrarian Relations.
While there is no further appeal from a decision of the President, such a decision—and by extension, a decision of the Minister acting as the President’s alter ego—may be reviewed by the courts through the special civil actions of certiorari, prohibition, or mandamus under Rule 65 of the Rules of Court. The Court of Appeals has concurrent jurisdiction with the Supreme Court and the Regional Trial Courts over these extraordinary writs. Therefore, Almine’s petition before the Court of Appeals, which essentially sought review of the Minister’s decision for grave abuse of discretion, was a proper subject for its certiorari jurisdiction. The failure to appeal to the Office of the President was not a fatal violation of the exhaustion doctrine, as the Minister is considered the alter ego of the President. The case was remanded to the Court of Appeals for further proceedings.