Case Digest: Land Bank of the Philippines vs Celada, 479 SCRA 495 ,G.R. No. 164876, January 23, 2006

Land Bank of the Philippines vs. Celada
479 SCRA 495 ,
G.R. No. 164876
January 23, 2006

Facts:
Respondent Leonila P. Celada, owns agricultural in Calatrava, Carmen, Bohol identified in 1998 by the DAR as suitable for compulsory acquisition under the CARP. LBP valued respondent's land at P2.1105517 per square meter for an aggregate value of P299,569.61. The DAR offered the same amount, but it was rejected.

The matter was referred to DARAB Region VII-Cebu City, for summary administrative hearing on determination of just compensation.
While the DARAB case was pending, respondent filed, on February 10, 2000, a petition for judicial determination of just compensation against LBP, the DAR and the Municipal Agrarian Reform Officer (MARO) of Carmen, Bohol, before the Regional Trial Court of Tagbilaran City.

Issue:
Whether or not the SAC a quo erred in assuming jurisdiction over the petition for determination of just compensation while administrative proceedings is on-going before the DARAB, Region VII, Cebu City.

Held:
No. In Land Bank of the Philippines v. Court of Appeals, the landowner filed an action for determination of just compensation without waiting for the completion of the DARAB’s re-evaluation of the land. The Court nonetheless held therein that the SAC acquired jurisdiction over the action for the following reason:
It is clear from Sec. 57 that the RTC, sitting as a Special Agrarian Court, has ‘original and exclusive jurisdiction over all petitions for the determination of just compensation to landowners.’ This ‘original and exclusive’ jurisdiction of the RTC would be undermined if the DAR would vest in administrative officials original jurisdiction in compensation cases and make the RTC an appellate court for the review of administrative decision. Thus, although the new rules speak of directly appealing the decision of adjudicators to the RTCs sitting as Special Agrarian Courts, it is clear from Sec. 57 that the original and exclusive jurisdiction to determine such cases is in the RTCs. Any effort to transfer such jurisdiction to the adjudicators and to convert the original jurisdiction of the RTCs into appellate jurisdiction would be contrary to Sec. 57 and therefore would be void. Thus, direct resort to the SAC by private respondent is valid.It would be well to emphasize that the taking of property under RA No. 6657 is an exercise of the power of eminent domain by the State. The valuation of property or determination of just compensation in eminent domain proceedings is essentially a judicial function which is vested with the courts and not with administrative agencies. Consequently, the SAC properly took cognizance of respondent’s petition for determination of just compensation.