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REPUBLIC v. CA

This case has been cited 9 times or more.

2012-04-11
VILLARAMA, JR., J.
Petitioners contend that there is no statutory basis for the promulgation of the DARAB procedure providing for a mode of appeal and a reglementary period to appeal.  On the matter of whether the DARAB Rules of Procedure laid out an appeal process and the validity of the 15-day reglementary period has already been laid to rest, the Court, in Republic v. Court of Appeals[17] and subsequent cases[18] has clarified that the determination of the amount of just compensation by the DARAB is merely a preliminary administrative determination which is subject to challenge before the SACs which have original and exclusive jurisdiction over all petitions for the determination of just compensation under Section 57, R.A. No. 6657.  In Republic v. Court of Appeals, we ruled
2011-07-27
VILLARAMA, JR., J.
In Republic v. Court of Appeals,[21] private respondent landowner rejected the government's offer of its lands based on LBP's valuation and the case was brought before the PARAD which sustained LBP's valuation.  Private respondent then filed a Petition for Just Compensation in the RTC sitting as Special Agrarian Court.  However, the RTC dismissed its petition on the ground that private respondent should have appealed to the DARAB, in accordance with the then DARAB Rules of Procedure.  Additionally, the RTC found that the petition had been filed more than fifteen days after notice of the PARAD decision.  Private respondent then filed a petition for certiorari in the CA which reversed the order of dismissal of RTC and remanded the case to the RTC for further proceedings. The government challenged the CA ruling before this Court via a petition for review on certiorari.  This Court, affirming the CA, ruled as follows: Thus, under the law, the Land Bank of the Philippines is charged with the initial responsibility of determining the value of lands placed under land reform and the compensation to be paid for their taking. Through notice sent to the landowner pursuant to §16(a) of R.A. No. 6657, the DAR makes an offer. In case the landowner rejects the offer, a summary administrative proceeding is held and afterward the provincial (PARAD), the regional (RARAD) or the central (DARAB) adjudicator as the case may be, depending on the value of the land, fixes the price to be paid for the land.  If the landowner does not agree to the price fixed, he may bring the matter to the RTC acting as Special Agrarian Court.  This in essence is the procedure for the determination of compensation cases under R.A. No. 6657.  In accordance with it, the private respondent's case was properly brought by it in the RTC, and it was error for the latter court to have dismissed the case.  In the terminology of §57, the RTC, sitting as Special Agrarian Court, has "original and exclusive jurisdiction over all petitions for the determination of just compensation to landowners." It would subvert this "original and exclusive" jurisdiction of the RTC for the DAR to vest original jurisdiction in compensation cases in administrative officials and make the RTC an appellate court for the review of administrative decisions.
2010-08-11
VILLARAMA, JR., J.
Under the law, the LBP is charged with the initial responsibility of determining the value of lands placed under land reform and the compensation to be paid for their taking.[12]  Once an expropriation proceeding or the acquisition of private agricultural lands is commenced by the DAR, the indispensable role of LBP begins.  EO No. 405, issued on June 14, 1990, provides that the DAR is required to make use of the determination of the land valuation and compensation by the LBP as the latter is primarily responsible for the determination of the land valuation and compensation.  In fact, the LBP can disagree with the decision of the DAR in the determination of just compensation, and bring the matter to the RTC designated as SAC for final determination of just compensation.[13]
2009-06-26
PERALTA, J.
In Republic v. CA,[5] the Court explained:Thus, Special Agrarian Courts, which are Regional Trial Courts, are given original and exclusive jurisdiction over two categories of cases, to wit: (1) "all petitions for the determination of just compensation to landowners" and (2) "the prosecution of all criminal offenses under [R.A. No. 6657]." The provisions of §50 must be construed in harmony with this provision by considering cases involving the determination of just compensation and criminal cases for violations of R.A. No. 6657 as excepted from the plenitude of power conferred on the DAR. Indeed, there is a reason for this distinction. The DAR is an administrative agency which cannot be granted jurisdiction over cases of eminent domain (for such are takings under R.A. No. 6657) and over criminal cases. Thus, in EPZA v. Dulay and Sumulong v. Guerrero - we held that the valuation of property in eminent domain is essentially a judicial function which cannot be vested in administrative agencies, while in Scoty's Department Store v. Micaller, we struck down a law granting the then Court of Industrial Relations jurisdiction to try criminal cases for violations of the Industrial Peace Act.[6]
2009-06-26
PERALTA, J.
where DARAB acknowledges that the decision of just compensation cases for the taking of lands under RA 6657 is a power vested in the courts.[13] Although Section 5, Rule XIX of the 2003 DARAB Rules of Procedure provides that the land valuation cases decided by the adjudicator are now appealable to the Board, such rule could not change the clear import of Section 57 of RA No. 6657 that the original and exclusive jurisdiction to determine just compensation is in the RTC. Thus, Section 57 authorizes direct resort to the SAC in cases involving petitions for the determination of just compensation.[14] In accordance with the said Section 57, petitioner properly filed the petition before the RTC and, hence, the RTC erred in dismissing the case. Jurisdiction over the subject matter is conferred by law.[15] Only a statute can confer jurisdiction on courts and administrative agencies while rules of procedure cannot.[16]
2006-05-05
AZCUNA, J.
In the implementation of the CARP, the Special Agrarian Courts which are the Regional Trial Courts, are given original and exclusive jurisdiction over two categories of cases, to wit: (1) all petitions for the determination of just compensation to landowners; and, (2) the prosecution of all criminal offenses under R.A. No. 6657.[32] What agrarian adjudicators are empowered to do is only to determine in a preliminary manner the reasonable compensation to be paid to the landowners, leaving to the courts the ultimate power to decide the question.[33]
2006-05-05
AZCUNA, J.
In the implementation of the CARP, the Special Agrarian Courts which are the Regional Trial Courts, are given original and exclusive jurisdiction over two categories of cases, to wit: (1) all petitions for the determination of just compensation to landowners; and, (2) the prosecution of all criminal offenses under R.A. No. 6657.[32] What agrarian adjudicators are empowered to do is only to determine in a preliminary manner the reasonable compensation to be paid to the landowners, leaving to the courts the ultimate power to decide the question.[33]
2006-05-05
AZCUNA, J.
The procedure for the determination of the compensation for the landowners under the land reform program was likewise outlined by this Court in Republic v. Court of Appeals:[34]
2005-10-13
AZCUNA, J.
Settled is the rule that jurisdiction is conferred only by the Constitution or the law.[14] Republic v. Court of Appeals[15] also enunciated that only a statute can confer jurisdiction on courts and administrative agencies.