25 June 1997 – on motion by the farmer-beneficiaries, the RTC
4.SPRINGFIELD V RTC JUDGE dismissed the case for lack of jurisdiction
GR NO. 142628 2 July 1997 – Springfield and Piit filed with the CA a special civil action for FEBRUARY 6, 2007 certiorari, mandamus, and prohibition with prayer for the issuance of writ Topic: Jurisdiction of preliminary injunction and/or TRO Petitioners: Springfield Development Corp Inc. o Alleged that the RTC committed grave abuse of discretion when Respondents: RTC Judge it ruled that the annulment of judgment filed before it is Ponente: Austria-Martinez actually an action for certiorari in a different color o Stated that what it sought before the RTC is an annulment of RECIT-READY/SUMMARY: A DARAB decision was appealed to the RTC for the DARAB Decision and not certiorari, as the DARAB Decision is annulment but the RTC dismissed the appeal for lack of jurisdiction. The Court held that the RTC has the power to annul judgments of inferior courts and quasi-judicial void ab initio for having been rendered without due process of law. bodies of equal ranking to such inferior courts but not those of courts and quasi- judicial bodies of equal ranking to the RTC. 16 July 1998 – CA dismissed the petition ruling that RTC does not have jurisdiction to annul the DARAB Decision because it is a co-equal body Doctrine: The RTC does not have the power to annul a decision rendered by a court or quasi-judicial body of equal ranking. 12 January 1999 – CA ordered the elevation of the DARAB records before it declaring that it overlooked the fact that Springfield and Piit likewise FACTS: applied for a writ of prohibition against the enforcement of the DARAB decision which they claim to be patently void. Petra Piit previously owned a lot in Cagayan de Oro (CDO). A portion of this lot was sold to Springfield which then developed the property into a 23 February 2000 – CA dismissed the MR without specifically resolving subdivision called Mega Heights Subdivision the issue regarding the writ of prohibition 4 May 1990 – DAR, through its Municipal Agrarian Reform Officer, issued ISSUE: a Notice of Coverage placing the property under the coverage of RA 6657 or the Comprehensive Agrarian Reform Law (CARL) of 1988 Does the RTC have jurisdiction to annul a final judgment of the DARAB? o No. The RTC does not have the power to annul a decision rendered 27 August 1991 – DARAB Provincial Adjudicator Salcedo declared the by a court or quasi-judicial body of equal ranking. property as residential and not suitable for agriculture. DAR Regional Director filed a petition for relied from judgment of the HELD/RATIO: DARAB decision The petition for annulment of the DARAB decision was filed with the RTC on 5 October 1995 – DARAB granted the petition June 13, 1997, before the advent of the 1997 Rules of Civil Procedure, which o It directed the Municipal Agrarian Reform Office to proceed took effect on July 1, 1997. Thus, the applicable law is B.P. Blg.129 or the with the documentation, acquisition, and distribution of the Judiciary Reorganization Act of 1980, enacted on August 10, 1981. property to the true and lawful beneficiaries. o Before BP 129, a CFI has the authority to annul a final and executory 22 May 1997 – DARAB ordered the heir of Piit and Springfield to pay the judgment rendered by another CFI or by another branch of the same farmer-beneficiaries P12,340,800.00 corresponding to the value of the court. But in later cases, the Court held that the better policy, as a property since the property has already been developed into a matter of comity or courteous interaction between courts of first subdivision. instance and the branches thereof, is for the annulment cases to be 13 June 1997 - Springfield and the heirs of Piit filed with the RTC of CDO a tried by the same court or branch which heard the main action. petition for annulment of the DARAB Decision dated October 5, 1995 and With the introduction of BP 129, the rule on annulment of judgments was all its subsequent proceedings specifically provided in Section 9(2) which vested in the then IAC the exclusive o They contend that the DARAB decision was rendered without original jurisdiction over actions for annulment of judgments of RTCs. affording petitioners any notice and hearing. According to the Interim Rules and Guidelines implementing B.P. Blg. 129, the quasi-judicial bodies whose decisions are exclusively appealable to the CA are those, which under the law, R.A. No. 5434,2 or its enabling acts, are specifically appealable to the CA. BP 129 does not specifically provide for any power of the RTC to annul judgments of quasi-judicial bodies. But in the case of BF Northwest Homeowners Association, Inc. v. IAC, the Court held that RTCs have jurisdictions over action for annulment of judgments of inferior courts and administrative or quasi-judicial bodies of equal ranking with such inferior courts. DARAB is a a quasi-judicial body created by Executive Order Nos. 229 and 129-A. R.A. No. 6657 allocated its adjudicatory powers and functions. o The rule is that where legislation provides for an appeal from decisions of certain administrative bodies to the CA, it means that such bodies are co-equal with the RTC, in terms of rank and stature, and logically, beyond the control of the latter. Given that DARAB decisions are appealable to the CA, the inevitable conclusion is that the DARAB is a co-equal body with the RTC and its decisions are beyond the RTC's control.
Judgment: The petition is PARTLY GRANTED and is remanded to the CA which
is directed to resolve the prayer for the issuance of the writ of prohibition.