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JurisprudenceG.R. No. 122256 -

G.R. No. 122256 - REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE DEPARTMENT OF AGRARIAN REFORM (DAR), AND LAND BANK OF THE PHILIPPINES, VS. COURT OF APPEALS AND ACIL CORPORATION.

Cited Laws

RA 366RA 536RA 305RA 461RA 609RA 558RA 6657,RA 6657
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TL;DR — Ruling

the case was remanded to the RTC for further proceedings.

Decision

Ruling

Accordingly, the case was remanded to the RTC for further proceedings. In turn the government, represented by the Department of Agrarian Reform, filed this petition for review on certiorari, raising as the issue whether in cases involving claims for just compensation under R.A. No. 6657 an appeal from the decision of the provincial adjudicator to the DARAB must first be made before a landowner can resort to the RTC under §57. Petitioners sustain the affirmative proposition. They cite §50 of R.A. No. 6657 which in pertinent part provides: §50. Quasi-judicial Powers of the Dar. - The DAR is hereby vested with primary jurisdiction to determine and adjudicate agrarian reform matters and shall have exclusive original jurisdiction over all matters involving the implementation of agrarian reform, except those falling under the exclusive jurisdiction of the Department of Agriculture (DA) and the Department of Environment and Natural Resources (DENR)... and argue that the fixing of just compensation for the taking of lands under R.A. No. 6657 is a "[matter] involving the implementation of agrarian reform" within the contemplation of this provision. They invoke §16(f) of R.A. No. 6657, which provides that "any party who disagrees to the decision [of the DAR] may bring the matter to the court of proper jurisdiction for final determination of just compensation," as confirming their construction of §50. The contention has no merit. It is true that §50 grants the DAR primary jurisdiction to determine and adjudicate "agrarian reform matters" and exclusive original jurisdiction over "all matters involving the implementation of agrarian reform," except those falling under the exclusive jurisdiction of the Department of Agriculture and the Department of Environment and Natural Resources. It is also true, however, that §57 provides: §57. Special jurisdiction. - The Special Agrarian Court shall have original and exclusive jurisdiction over all petitions for the determination of just compensation to landowners, and the prosecution of all criminal offenses under this Act. the Rules of Court shall apply to all proceedings before the Special Agrarian Courts, unless modified by this Act. The Special Agrarian Courts shall decide all appropriate cases under their special jurisdiction within thirty (30) days from submission of the case for decision. 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]." [2] 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 age