DARAB vs. Lubrica

A quasi-judicial agency cannot exercise original jurisdiction to issue a writ of certiorari absent an express statutory or constitutional grant, as such jurisdiction is never derived by implication and cannot be self-conferred through rule-making or supervisory authority over subordinate adjudicators.

Federico Suntay, assignor of respondent Josefina Lubrica, owned 948.1911 hectares of land in Sablayan, Occidental Mindoro, subject of agrarian reform. The DAR and Land Bank of the Philippines (Land Bank) valued the property at ₱4,251,141.68. Deeming the valuation unconscionably low, Suntay filed a petition for fixing and payment of just compensation before the RARAD. The RARAD fixed the compensation at ₱157,541,951.30. Land Bank's motion for reconsideration was denied, and notice of denial was received on March 26, 2001. Land Bank subsequently filed a petition for just compensation with the Regional Trial Court (RTC) sitting as a Special Agrarian Court (SAC) on April 20, 2001. Because this filing was beyond the 15-day reglementary period under the DARAB Rules, the RARAD declared its decision final and executory and issued a writ of execution. Land Bank then filed a petition for certiorari with the DARAB to nullify the RARAD's issuances.

• The Property and Valuation: Federico Suntay owned landholdings covering 948.1911 hectares in Sablayan, Occidental Mindoro, embraced under Transfer Certificate of Title T-31. The DAR and Land Bank valued the property at ₱4,251,141.68, or ₱4,497.50 per hectare.
• Petition Before the RARAD: Suntay assigned his rights over the property to respondent Josefina Lubrica. Suntay filed a petition for fixing and payment of just compensation against DAR and Land Bank before the RARAD, docketed as DARAB Case No. V-0405-0001-00, alleging the DAR and Land Bank valuation was unconscionably low.
• RARAD Decision and Finality: The RARAD rendered a decision on January 24, 2001, ordering Land Bank to pay ₱157,541,951.30 as just compensation. Land Bank's motion for reconsideration was denied in an Order dated March 14, 2001, which Land Bank received on March 26, 2001.
• Resort to the Special Agrarian Court: On April 20, 2001, Land Bank filed a petition for just compensation with the RTC of San Jose, Occidental Mindoro, sitting as a Special Agrarian Court (Agrarian Case No. R-1241), praying that just compensation be declared at ₱4,251,141.00. Suntay moved to dismiss on grounds of lack of capacity to sue, lack of cause of action, and res judicata. The RTC dismissed the petition on August 6, 2001, for failure to pay docket fees within the reglementary period, and subsequently denied Land Bank's motion for reconsideration as pro-forma. Land Bank appealed the dismissal to the Court of Appeals.
• Execution and Certiorari Before the DARAB: Upon Suntay's motion, the RARAD declared its January 24, 2001 decision final and executory on May 22, 2001, noting Land Bank's filing with the SAC was beyond the 15-day reglementary period. The RARAD issued a Writ of Execution on July 18, 2001. Land Bank then filed a Petition for Certiorari with Prayer for TRO/Preliminary Injunction before the DARAB (DSCA No. 0252) to nullify the RARAD's decision, the order of finality, the denial of its motion for reconsideration, and the writ of execution. The DARAB issued an order enjoining the RARAD from implementing its decision.
• Prohibition Before the Court of Appeals: On September 20, 2001, Lubrica filed a Petition for Prohibition with the Court of Appeals (CA-G.R. SP No. 66710) to enjoin DARAB from proceeding with DSCA No. 0252, arguing DARAB lacked jurisdiction over special civil actions for certiorari. The CA granted the petition and perpetually enjoined DARAB from proceeding with the case.

• Jurisdiction over Certiorari: DARAB maintained that it has jurisdiction over DSCA No. 0252, arguing that the general rule requiring an express statutory grant for jurisdiction over special civil actions applies only when the officials or entities subject to the writ are not within the administrative power, control, or supervision of the issuing authority. DARAB claimed it exercised its residual power of supervision to ensure the RARAD acted within the bounds of its delegated authority.
• Party Status: DARAB argued that the Court of Appeals erred in ruling that it should not have filed a comment in the prohibition proceedings because it was a mere formal party.
• Validity of Injunction: DARAB contended that the writ of preliminary injunction it issued in DSCA No. 0252 was valid and not issued in violation of the CA's temporary restraining order.

• Lack of Jurisdiction: Lubrica countered that R.A. No. 6657, which confers adjudicatory functions upon the DAR, does not grant DAR jurisdiction over special civil actions for certiorari.
• Nullity of Injunction and Contempt: Lubrica sought to nullify the writ of preliminary injunction issued by DARAB in DSCA No. 0252 and to cite DARAB for contempt, arguing it violated the CA's temporary restraining order.
• Prematurity and Lack of Personality: Land Bank, as co-respondent, argued that Lubrica's petition for prohibition was premature because the issue of DARAB's jurisdiction could be elevated to the DAR Secretary under the doctrine of exhaustion of administrative remedies. Land Bank also questioned Lubrica's personality to file the petition, noting she never intervened in the RARAD proceedings.

• Jurisdiction over Certiorari: Whether the DARAB has jurisdiction to take cognizance of a petition for certiorari assailing the decisions or orders of its subordinates, the RARADs.
• Party Status: Whether the DARAB, as a formal party, erred in filing a comment before the Court of Appeals in the petition for prohibition.
• Validity of Injunction: Whether the writ of preliminary injunction issued by the DARAB in DSCA No. 0252 was null and void for having been issued in violation of the temporary restraining order issued by the Court of Appeals.

• Jurisdiction over Certiorari: Jurisdiction over the petition for certiorari was correctly denied to the DARAB. The authority to issue writs of certiorari involves the exercise of original jurisdiction, which must be expressly conferred by the Constitution or law and is never derived by implication. R.A. No. 6657, E.O. No. 229, and E.O. No. 129-A do not contain an express grant of such jurisdiction to the DARAB. The DARAB's quasi-judicial authority and rule-making power do not justify self-conferment of jurisdiction. While the DARAB has supervisory authority over RARADs and PARADs, this must be exercised within the context of administrative supervision and control, not by arrogating the power to correct errors of jurisdiction through certiorari, which is lodged with regular courts.
• Party Status: The DARAB's filing of a comment before the Court of Appeals was not improper. The DARAB has a peculiar interest in the final outcome of the case because it is composed of senior DAR officials guided by the State's main policy in agrarian reform. Its interest is not purely legal but also a matter of governance; thus, it cannot be strictly considered a nominal party required to refrain from taking an active part in the proceedings.
• Validity of Injunction: The writ of preliminary injunction issued by the DARAB was effectively nullified because the DARAB lacked jurisdiction to entertain the certiorari petition in the first place.

• Jurisdiction of Quasi-Judicial Bodies over Extraordinary Writs — The authority to issue writs of certiorari, prohibition, and mandamus involves the exercise of original jurisdiction which must be expressly conferred by the Constitution or by law. It is never derived by implication. In the absence of a specific statutory grant, a quasi-judicial body with limited jurisdiction cannot exercise jurisdiction over a petition for certiorari. Neither its quasi-judicial authority nor its rule-making power justifies such self-conferment.
• Distinction Between Procedure and Jurisdiction — Procedure is the means by which the power or authority of a court to hear and decide a class of cases is put into action. Rules of procedure are remedial in nature and not substantive, covering only rules on pleadings and practice. The statutory allowance for an agency to adopt its own rules of procedure does not permit it to grant itself jurisdiction, which is substantive and must be conferred by the Constitution or law.

• "In the absence of a specific statutory grant of jurisdiction to issue the said extraordinary writ of certiorari, the DARAB, as a quasi-judicial body with only limited jurisdiction, cannot exercise jurisdiction over Land Bank’s petition for certiorari. Neither the quasi-judicial authority of the DARAB nor its rule-making power justifies such self-conferment of authority."
• "The grant of original jurisdiction on a quasi-judicial agency is not implied. There is no question that the legislative grant of adjudicatory powers upon the DAR, as in all other quasi-judicial agencies, bodies and tribunals, is in the nature of a limited and special jurisdiction, that is, the authority to hear and determine a class of cases within the DAR’s competence and field of expertise."

• Garcia v. De Jesus, G.R. No. 88158, March 4, 1992 — Followed. Cited for the definition of jurisdiction and the principle that the authority to issue writs of certiorari must be expressly conferred by law.
• Garcia, Jr. v. Sandiganbayan, G.R. No. 114135, October 7, 1994 — Followed. Cited for the rule that the power to issue writs of certiorari, prohibition, and mandamus involves the exercise of original jurisdiction which must be expressly conferred.
• Philippine Veterans Bank vs. Court of Appeals, 379 Phil. 141 (2000) — Applied. Cited as controlling precedent affirming the dismissal of a petition for judicial determination of just compensation for failure to file within the 15-day reglementary period under Rule XIII, §11 of the DARAB Rules of Procedure.
• Antipolo Realty Corporation v. The National Housing Authority, G.R. No. L-50444, August 31, 1987 — Followed. Cited for the principle that the quantum of judicial or quasi-judicial powers an administrative agency may exercise is defined in its enabling act.

• Section 50, Republic Act No. 6657 — Vests the DAR with primary jurisdiction to determine and adjudicate agrarian reform matters and exclusive original jurisdiction over matters involving the implementation of agrarian reform, and grants the power to adopt a uniform rule of procedure. Applied to delineate the scope of DAR's adjudicatory powers, noting the absence of an express grant of jurisdiction to issue writs of certiorari.
• Section 17, Executive Order No. 229 & Section 13, Executive Order No. 129-A — Created the DARAB as the quasi-judicial arm of the DAR and authorized the DAR to delegate its adjudicatory powers to regional offices. Applied to establish the origin and limited nature of DARAB's jurisdiction.
• Rule XIII, Section 11, DARAB Rules of Procedure — Provides that the decision of the Adjudicator on land valuation and preliminary determination and payment of just compensation shall be brought directly to the RTC designated as Special Agrarian Courts within 15 days from receipt of notice. Applied to determine that Land Bank's filing with the RTC was beyond the reglementary period, rendering the RARAD decision final and executory.

Puno, C.J. (Chairman), Austria-Martinez, Callejo, Sr., and Chico-Nazario, JJ.