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(case no.

583)

REPUBLIC v. COURT OF APPEALS


GR Number 122256
October 30, 1996
Art. III
FACTS:
Private respondent (ACIL Corporation) owned several hectares of land in Linoan,
Montevista, Davao del Norte, which the government took pursuant to RA 6657 or the
Comprehensive Agrarian Reform Law. The certificates of title were cancelled and new ones were
issued and distributed to the farmer-beneficiaries.
The lands were valued by the Land Bank of the Philippines at Php19,312.24 per hectare
for the Riceland and Php4267.68 per hectare for brushland, for a total of Php439,105.39. But in
the Statement of Agricultural Landholdings, the value of the land was pegged uniformly at
Php15,311.79 per hectare and fixed the amount of Php390,557.84 as the total compensation to be
paid for the lands.
Private respondent rejected the offer of the government pointing out that nearby lands
planting the same crops were valued at a higher price of Php24,71740 per hectare. The matter
was brought before the Provincial Agrarian Reform Adjudicator (PARAD) but the initial
valuation of Land Bank was sustained. A petition was filed with the RTC but it was dismissed on
the ground that private respondent should have appealed to the DAR Adjudication Board
(DARAB) pursuant to the Revised Rules of Procedure. CA reversed the dismissal order of the
RTC.
The government, represented by DAR, filed the present petition for review.
ISSUE:
Whether cases involving claims for just compensation under RA 6657 must first be made
in the DARAB before resorting to RTC under Rule 57.
HELD:
No. While Rule 50 grants DAR primary jurisdiction to determine and adjudicate agrarian
reform matters and exclusive original jurisdiction over all matters involving the implementation
of agrarian reform, Rule 57 provides that Special Agrarian Courts shall decide all
appropriate cases under their special jurisdiction within 30 days from submission of the
case for decision. Special Agrarian Courts are the Regional Trial Courts and are given original
and exclusive jurisdiction over 2 categories of cases: (1) all petitions for the determination of
just compensation to landowners and (2) prosecution of criminal offenses under RA 6657.
Provision of Rule 50 must be construed in harmony with Rule 57. The DAR, as an
administrative agency, cannot be granted jurisdiction over cases of eminent domain. Any
effort to transfer the jurisdiction to the adjudicators would be contrary to Rule 57 and would
therefore be void. What the adjudicators are empowered to do is only to determine in a
preliminary manner the reasonable compensation to be paid to the landowners, leaving to
the courts the ultimate power to decide this question.

Prepared by: Cecille Diane DJ. Mangaser