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Vda. de Tangub vs. Court of Appeals
GR No. 9864
191 SCRA 885 , December 03, 1990
Rufina Tangub and her husband, Andres, now deceased, filed with the Regional Trial Court of Lanao del Norte in March, 1988, "an agrarian case for damages by reason of the(ir) unlawful dispossession . . .was tenants from the landholding" owned by the Spouses Domingo and Eugenia Martil. Several persons were also impleaded as defendants, including the Philippine National Bank, it being alleged by the plaintiff spouses that said bank, holder of a mortgage on the land involved, had caused foreclosure thereof, resulting in the acquisition of the property by the bank as the highest bidder at the foreclosure sale, and in the sale by the latter, some time later, of portions of the land to the other persons named as its co-defendants (all employees of the National Steel Corporation), and it being prayed that mortgage and the transactions thereafter made in relation thereto be annulled and voided.
In an Order rendered on August 24, 1988, respondent Judge Felipe G. Javier, Jr. dismissed the complaint. He opined that by virtue of Executive Order No. 229 "providing the mechanisms for the implementation of the Comprehensive Agrarian Reform Program approved on July 24, 1987" — Executive No. 129-A approved on July 26,1987, as well as the Rules of the Adjudication Board of the Department of Agrarian Reform, jurisdiction of the Regional Trial Court over agrarian cases had been transferred to the Department of Agrarian Reform.
Court of Appeals upheld decision of Trial Court.
Whether or not the Regional Trial Court of Iligan City was correct in dismissing Agrarian Case No. 1094.
Yes. RA 6657 echoes the provisions of Section 17 of Presidential Decree No. 229, supra, investing the Department of Agrarian Reform with original jurisdiction, generally, over all cases involving agrarian laws, although, as shall shortly be pointed out, it restores to the Regional Trial Court, limited jurisdiction over two groups of cases. Section 50 reads as follows:
"SEC. 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].
It shall not be bound by technical rules of procedure and evidence but shall proceed to hear and decide all cases, disputes or controversies in a most expeditious manner, employing all reasonable means to ascertain the facts of every case in accordance with justice and equity and the merits of the case. Toward this end, it shall adopt a uniform rule of procedure to achieve a just, expeditious and inexpensive determination of every action or proceeding before it.
It shall have the power to summon witnesses, administer oaths, take testimony, require submission of reports, compel the production of books and documents and answers to interrogatories and issue subpoena and subpoena duces tecum and to enforce its writs through sheriffs or other duly deputized officers. It shall likewise have the power to punishdirect and indirect contempts in the same manner and subject to the same penalties as provided in the Rules of Court.
Section 56 of RA 6657, on the other hand, confers "special jurisdiction" on "Special Agrarian Courts," which are Regional Trial Courts designated by the Supreme Court — at least one (1) branch within each province — to act as such. These Regional Trial Courts qua Special Agrarian Courts have, according to Section 57 of the same law, original and exclusive jurisdiction over:
1) "all petitions for the determination of just compensation to land-owners," and
2) "the prosecution of all criminal offenses under . . [the] Act."
It is relevant to mention in this connection that --
(1) appeals from decisions of the Special Agrarian Courts "may be taken by filing a petition for review with the Court of Appeals within fifteen (15) days from receipt or notice of the decision, . ." [Sec. 60]and
(2) appeals from any "decision, order, award or ruling of the DAR on any agrarian dispute or on any matter pertaining to the application, implementation, enforcement, or interpretation of this Act and other pertinent laws on agrarian reform may be brought to the Court of Appeals by Certiorari* except as otherwise provided . . . within fifteen (15) days from receipt of a copy thereof," the "findings of fact of the DAR [being] final and conclusive if based on substantial evidence." [Sec. 54]
Hence, the DAR has original, exclusive jurisdiction over agrarian disputes, except on the aspects of (a) justcompensation; and (b) criminal jurisdiction over which regular courts have jurisdiction. Here, the case concerns the rights of the plaintiffs as tenants on agricultural land, not involving the "special jurisdiction" of said Trial Court acting as a Special Agrarian Court, it clearly came within the exclusive original jurisdiction of the Department of Agrarian Reform, or more particularly, the Agrarian Reform Adjudication Board, established precisely to wield the adjudicatory powers of the Department.
*[This mode of appeal is sui generis. It is the only instance when an appeal by Certiorari may be taken to the Court of Appeals. Heretofore, appeals by Certiorari were authorized only when taken to the Supreme Court.]