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Springfield Development Corporation, Inc. v.

Presiding ○ The decision became final and executory and


Judge, RTC, Misamis Oriental, Br. 40, Cagayan de Oro City Springfield continued with the development of the
6 February 2007 | Ponente: Austria-Martinez property.
● DAR Regional Director filed a petition for relied from
Overview: A DARAB decision was appealed to the RTC for judgment of the DARAB decision
annulment but the RTC dismissed the appeal for lack of ● 5 October 1995 – DARAB granted the petition
jurisdiction. The Court held that the RTC has the power to annul ○ It directed the Municipal Agrarian Reform Office to
judgments of inferior courts and quasi-judicial bodies of equal proceed with the documentation, acquisition, and
ranking to such inferior courts but not those of courts and quasi- distribution of the property to the true and lawful
judicial bodies of equal ranking to the RTC. beneficiaries.
● 22 May 1997 – DARAB ordered the heir of Piit and
Statement of the Case Springfield o pay the farmer-beneficiaries P12,340,800.00
● DARAB declared Springfield under the coverage of CARL corresponding to the value of the property since the
and ordered it to pay the farmer-beneficiaries. property has already been developed into a subdivision.
● RTC dismissed the case for lack of jurisdiction ● 13 June 1997 - Springfield and the heirs of Piit filed with
● CA dismissed the action for lack of merit ruling that the the RTC of CDO a petition for annulment of the DARAB
RTC does not have jurisdiction to annul the DARAB Decision dated October 5, 1995 and all its subsequent
Decision because it is a co-equal body proceedings
○ They contend that the DARAB decision was
Statement of Facts rendered without affording petitioners any notice
● Petra Piit previously owned a lot in Cagayan de Oro and hearing.
(CDO). A portion of this lot was sold to Springfield which ● 25 June 1997 – on motion by the farmer-beneficiaries, the
then developed the property into a subdivision called Mega RTC dismissed the case for lack of jurisdiction
Heights Subdivision ● 2 July 1997 – Springfield and Piit filed with the CA a
● 4 May 1990 – DAR, through its Municipal Agrarian Reform special civil action for certiorari, mandamus, and
Officer, issued a Notice of Coverage placing the property prohibition with prayer for the issuance of writ of
under the coverage of RA 6657 or the Comprehensive preliminary injunction and/or TRO
Agrarian Reform Law (CARL) of 1988 ○ Alleged that the RTC committed grave abuse of
○ Piit opposed said coverage discretion when it ruled that the annulment of
● 27 August 1991 – DARAB Provincial Adjudicator Salcedo judgment filed before it is actually an action for
declared the property as residential and not suitable for certiorari in a different color
agriculture ○ Stated that what it sought before the RTC is an
○ The Regional Director filed a notice of appeal which annulment of the DARAB Decision and not
Salcedo disallowed for being pro forma and certiorari, as the DARAB Decision is void ab initio
frivolous for having been rendered without due process of
law.
● 16 July 1998 – CA dismissed the petition ruling that RTC In Ngo Bun Tiong v. Sayo, the Court expressed that pursuant to
does not have jurisdiction to annul the DARAB Decision the policy of judicial stability, the doctrine of non-interference
because it is a co-equal body between concurrent and coordinate courts should be regarded as
● 12 January 1999 – CA ordered the elevation of the DARAB highly important in the administration of justice whereby the
records before it declaring that it overlooked the fact that judgment of a court of competent jurisdiction may not be opened,
Springfield and Piit likewise applied for a writ of prohibition modified or vacated by any court of concurrent jurisdiction.
against the enforcement of the DARAB decision which they
claim to be patently void. With the introduction of BP 129, the rule on annulment of
● 23 February 2000 – CA dismissed the MR without judgments was specifically provided in Section 9(2) which vested
specifically resolving the issue regarding the writ of in the then IAC the exclusive original jurisdiction over actions for
prohibition annulment of judgments of RTCs. According to the Interim Rules
and Guidelines implementing B.P. Blg. 129, the quasi-judicial
Applicable Laws: bodies whose decisions are exclusively appealable to the CA are
BP 129 or the Judiciary Reorganization Act of 1980. those, which under the law, R.A. No. 5434,24 or its enabling acts,
are specifically appealable to the CA.
Issues:
Does the RTC have jurisdiction to annul a final judgment of the BP 129 does not specifically provide for any power of the RTC to
DARAB? No. The RTC does not have the power to annul a annul judgments of quasi-judicial bodies. But in the case of BF
decision rendered by a court or quasi-judicial body of equal Northwest Homeowners Association, Inc. v. IAC, the Court held
ranking. that RTCs have jurisdictions over action for annulment of
judgments of inferior courts and administrative or quasi-judicial
Rationale bodies of equal ranking with such inferior courts.
The petition for annulment of the DARAB decision was filed with
the RTC on June 13, 1997, before the advent of the 1997 Rules of DARAB is a a quasi-judicial body created by Executive Order Nos.
Civil Procedure, which took effect on July 1, 1997. Thus, the 229 and 129-A. R.A. No. 6657 delineated its adjudicatory powers
applicable law is B.P. Blg. 129 or the Judiciary Reorganization Act and functions. The DARAB Revised Rules of Procedure adopted
of 1980, enacted on August 10, 1981. on December 26, 1988 specifically provides for the manner of
judicial review of its decisions, orders, rulings, or awards. Rule
Before BP 129, a CFI has the authority to annul a final and XIV, Section 1 states:
executory judgment rendered by another CFI or by another branch
of the same court. But in later cases, the Court held that the better SECTION 1. Certiorari to the Court of Appeals. Any decision,
policy, as a matter of comity or courteous interaction between order, award or ruling by the Board or its Adjudicators on any
courts of first instance and the branches thereof, is for the agrarian dispute or on any matter pertaining to the application,
annulment cases to be tried by the same court or branch which implementation, enforcement or interpretation of agrarian reform
heard the main action. laws or rules and regulations promulgated thereunder, may be
brought within fifteen (15) days from receipt of a copy thereof, to
the Court of Appeals by certiorari, except as provided in the next
succeeding section. Notwithstanding an appeal to the Court of
Appeals the decision of the Board or Adjudicator appealed from,
shall be immediately executory.

Further, the prevailing 1997 Rules of Civil Procedure, as


amended, expressly provides for an appeal from the DARAB
decisions to the CA.

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. The CA
was therefore correct in sustaining the RTC's dismissal of the
petition for annulment of the DARAB Decision as the RTC does
not have any jurisdiction to entertain the same.

Related issue: WON the petition for annulment of the DARAB


judgment could be brought to the CA.
No. BP 129 vested CA the exclusive original jurisdiction over
actions for annulment of judgments but only those rendered by the
RTC. It does not expressly give the CA the power to annul
judgments of quasi-judicial bodies. Also, previous decisions held
that the silence of B.P. Blg. 129 on the jurisdiction of the CA to
annul judgments or final orders and resolutions of quasi-judicial
bodies like the DARAB indicates its lack of such authority.

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.

Notes: Wala na. Laverrn lag guythz, malapit na ang christmas


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