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JurisprudenceG.R. No. 221484 -

G.R. No. 221484 - ROBUSTUM AGRICULTURAL CORPORATION, VS. DEPARTMENT OF AGRARIAN REFORM AND LAND BANK OF THE PHILIPPINES.D E C I S I O N - Supreme Court E-Library

Cited Laws

RA 8532RA 9700RA 6657,RA 6657RA 9700,
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TL;DR — Ruling

the petition is really only an agrarian reform matter incidental to an on-going proceeding for compulsory land acquisition and distribution, jurisdiction to resolve the same - as is the case for the main proceeding itself - must rest too with the DAR.

Decision

Ruling

Accordingly, petitioner submits that its present petition for quieting of title and declaratory relief - given that it was only filed on August 14, 2015 - rightfully falls under the jurisdiction of the RTC. OUR RULING Petitioner misunderstands Section 30 of RA No. 9700. Section 30 of RA No. 9700 did not vest any kind of jurisdiction over any kind of case unto the regular courts. By its language, the provision is simply an authorization for the DAR to continue to process, bring to finality and execute " [a]ny case [or] proceeding involving the implementation of the [agrarian reform law] " already pending as of June 30, 2014 even beyond the said date. Nothing more. One of the " proceeding[s] involving the implementation of the [agrarian reform law] " contemplated under Section 30 of RA No. 9700 is that for compulsory land acquisition and distribution pursuant to Section 16 of RA No. 6657, as amended. Per established DAR regulations, a proceeding for compulsory land acquisition and distribution is deemed commenced by the issuance of a notice of coverage. Here, two (2) notices of coverage involving the subject land have already been issued before June 30, 2014. The first is the original notice of coverage for the mother estate referred to, and attached in, PARO II Mabunay's Transmittal of NOC to the Landowner-Transferee/s dated December 5, 2013. Another is the published notice of coverage dated June 11, 2014. The issuances of these notices indicate that a proceeding for compulsory land acquisition and distribution against PAI and petitioner, concerning the mother estate and the subject land, was already pending before June 30, 2014. As such, the DAR maintains its authority to bring the said proceeding into conclusion pursuant precisely to Section 30 of RA No. 9700. Given this context, it becomes apparent why the petition a quo , notwithstanding the date of its filing, must fail. The petition - as both parties readily concede - is a mere challenge to the efficacy of the notice of coverage published by the DAR. This kind of challenge, however, is undoubtedly a matter involving the implementation of agrarian reform which is only part and parcel of a proceeding for compulsory land acquisition and distribution. Since the sole question raised in the petition is really only an agrarian reform matter incidental to an on-going proceeding for compulsory land acquisition and distribution, jurisdiction to resolve the same - as is the case for the main proceeding itself - must rest too with the DAR. The authority given to the DAR under Section 30 of RA No. 9700 to conclude any agrarian reform proceeding pending as of June 30, 2014, by necessity , includes an authority for the same to continue exercising its quasi-judicial powers under Section 50 of RA No. 6657 with respect to any agrarian reform matter or controversy that may arise in such proceeding. In these lights, we find that the RTC only acted correctly in refusing to take cognizance of the petition a quo .