Republic of the Philippines

SUPREME COURT
Manila
SECOND DIVISION
G.R. No. 180384 March 26, 2010
LAND BANK O T!E P!"L"PP"NES, Petitioner,
vs.
CORA#ON M. $"LLEGAS, Respondent.
! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !
G.R. No. 1808%1
LAND BANK O T!E P!"L"PP"NES, Petitioner,
vs.
!E"RS O CATAL"NO $. NOEL a&' PROCULA P. S(, Respondents.
D E C I S I O N
ABAD, J.:
"hese consolidated cases
#
are about the $urisdiction of a Re%ional "rial Court &R"C',
actin% as a Special (%rarian Court, over $ust co)pensation cases involvin% a%ricultural
lands located outside its re%ular territorial $urisdiction but *ithin the province *here it is
desi%nated as a%rarian court under the Co)prehensive (%rarian Refor) +a* of #,--.
"he .acts and the Case
Petitioner +and /an0 of the Philippines &+and /an0' filed cases for deter)ination of $ust
co)pensation a%ainst respondent Cora1on M. Ville%as in Civil Case 2334!#5#45 and
respondent heirs of Catalino V. Noel and Procula P. S6 in Civil Case 2334!#5#,7 before
the R"C of Du)a%uete Cit6, /ranch 72, sittin% as a Special (%rarian Court for the
province of Ne%ros Oriental. Respondent Ville%as8 propert6 *as in 9ibai6o, :uihuln%an
Cit6, Ne%ros Oriental, *hile respondent heirs8 land *as in Nan%ca, /a6a*an Cit6,
Ne%ros Oriental. "hese lands happened to be outside the re%ular territorial $urisdiction of
R"C /ranch 72 of Du)a%uete Cit6.
On Septe)ber #7, 2334 R"C, /ranch 72 dis)issed Civil Case 2334!#5#45 for lac0 of
$urisdiction.
2
It ruled that, althou%h it had been desi%nated Special (%rarian Court for
Ne%ros Oriental, the desi%nation did not epand its territorial $urisdiction to hear a%rarian
cases under the territorial $urisdiction of the R"C, /ranch ;5 of :uihuln%an Cit6 *here
respondent Ville%as8 propert6 can be found.
On Nove)ber #;, 2334 R"C, /ranch 72 also dis)issed Civil Case 2334!#5#,7 for lac0
of $urisdiction. It pointed out that R"C, /ranch ;7 of /a6a*an Cit6 had $urisdiction over
the case since respondent heirs8 propert6 *as *ithin the latter court8s territorial
$urisdiction.
Petitioner +and /an0 )oved for the reconsideration of the dis)issal of the t*o cases but
R"C, /ranch 72 denied both )otions.
7
(%%rieved, +and /an0 directl6 filed this petitions
for certiorari
5
before this Court, raisin% a purel6 <uestion of la*.
Sole =uestion Presented
"he sole <uestion presented in these cases is *hether or not an R"C, actin% as Special
(%rarian Court, has $urisdiction over $ust co)pensation cases involvin% a%ricultural lands
located outside its re%ular $urisdiction but *ithin the province *here it is desi%nated as an
a%rarian court under the Co)prehensive (%rarian Refor) +a* of #,,-.
"he Court8s Rulin%
"he R"C, /ranch 72 based its order on Deput6 Court (d)inistrator &DC(' >enaida
Elepa?o8s opinion that sin%le sala courts have $urisdiction over a%rarian cases involvin%
lands located *ithin its territorial $urisdiction. (n R"C branch actin% as a special a%rarian
court, she clai)ed, did not have epanded territorial $urisdiction. DC( Elepa?o said@
A/Bein% a sin%le sala court, the Re%ional "rial Court, /ranch ;5, :uihuln%an,
Ne%ros Oriental, has $urisdiction over all cases, includin% a%rarian cases, co%ni1able b6
the Re%ional "rial Court e)anatin% fro) the %eo%raphical areas *ithin its territorial
$urisdiction.
.urther, the $urisdiction of the Special (%rarian Courts over a%rarian cases is co!etensive
*ith its territorial $urisdiction. (d)inistrative Order No. -3 dated Cul6 #-, #,-,, as
a)ended b6 (d)inistrative Order No. -3(!,3 dated .ebruar6 27, #,,3, did not epand
the territorial $urisdiction of the courts desi%nated as Special (%rarian Courts.
D
Respondent Ville%as
;
adopts DC( Elepa?o8s vie*. Ville%as points out that the
desi%nation of R"C, /ranch 72 as a Special (%rarian Court did not epand its territorial
$urisdiction. (lthou%h it has been desi%nated Special (%rarian Court for the Province of
Ne%ros Oriental, its $urisdiction as an R"C did not cover the *hole province.
Respondent Ville%as adds that, in hearin% $ust co)pensation cases, R"C, /ranch ;5 in
:uihuln%an Cit6 should be no different fro) the situation of other sin%le sala courts that
concurrentl6 hear dru%s and fa)il6!related cases even as the Supre)e Court has
desi%nated fa)il6 and dru%s courts in Du)a%uete Cit6 *ithin the sa)e province. .urther,
:uihuln%an Cit6 is )ore than #33 0ilo)eters fro) Du)a%uete Cit6 *here R"C, /ranch
72 sits. .or practical considerations, R"C, /ranch ;5 of :uihuln%an Cit6 should hear and
decide the case.
.or their part, on Cune #,, 233, respondent heirs of Noel infor)ed
4
the Court that
petitioner +and /an0 had alread6 paid the) for their land. Conse<uentl6, the6 have no
further interest in the outco)e of the case. It is not clear, ho*ever, if the trial court had
alread6 approved a settle)ent.1avvphi1
ECurisdictionE is the court8s authorit6 to hear and deter)ine a case. "he court8s
$urisdiction over the nature and sub$ect )atter of an action is conferred b6 la*.
-
In this
case, the la* that confers $urisdiction on Special (%rarian Courts desi%nated b6 the
Supre)e Court in ever6 province is Republic (ct &R.(.' ;;D4 or the Co)prehensive
(%rarian Refor) +a* of #,--. Sections D; and D4 are the relevant provisions@
SEC. D;. Special (%rarian Court. ! "he Supre)e Court shall desi%nate at least one &#'
branch of the Re%ional "rial Court &R"C' *ithin each province to act as a Special
(%rarian Court.
"he Supre)e Court )a6 desi%nate )ore branches to constitute such additional Special
(%rarian Courts as )a6 be necessar6 to cope *ith the nu)ber of a%rarian cases in each
province. In the desi%nation, the Supre)e Court shall %ive preference to the Re%ional
"rial Courts *hich have been assi%ned to handle a%rarian cases or *hose presidin%
$ud%es *ere for)er $ud%es of the defunct Court of (%rarian Relations.
"he Re%ional "rial Court &R"C' $ud%es assi%ned to said courts shall eercise said special
$urisdiction in addition to the re%ular $urisdiction of their respective courts.
SEC. D4. Special Curisdiction. ! "he Special (%rarian Courts shall have ori%inal and
eclusive $urisdiction over all petitions for the deter)ination of $ust co)pensation to
lando*ners, and the prosecution of all cri)inal offenses under this (ct. "he Rules of
Court shall appl6 to all proceedin%s before the Special (%rarian Courts unless )odified
b6 this (ct.
"he Special (%rarian Courts shall decide all appropriate cases under their special
$urisdiction *ithin thirt6 &73' da6s fro) sub)ission of the case for decision.
"he la* is clear. ( branch of an R"C desi%nated as a Special (%rarian Court for a
province has the ori%inal and eclusive $urisdiction over all petitions for the
deter)ination of $ust co)pensation in that province. In Republic v. Court of (ppeals,
,
the
Supre)e Court ruled that Special (%rarian Courts have ori%inal and eclusive
$urisdiction over t*o cate%ories of cases@ &#' all petitions for the deter)ination of $ust
co)pensation to lando*ners, and &2' the prosecution of all cri)inal offenses under R.(.
;;D4.
/6 EspecialE $urisdiction, Special (%rarian Courts eercise po*er in addition to or over
and above the ordinar6 $urisdiction of the R"C, such as ta0in% co%ni1ance of suits
involvin% a%ricultural lands located outside their re%ular territorial $urisdiction, so lon% as
the6 are *ithin the province *here the6 sit as Special (%rarian Courts.
R.(. ;;D4 re<uires the desi%nation b6 the Supre)e Court before an R"C /ranch can
function as a Special (%rarian Court. "he Supre)e Court has not desi%nated the sin%le
sala courts of R"C, /ranch ;5 of :uihuln%an Cit6 and R"C, /ranch ;7 of /a6a*an Cit6
as Special (%rarian Courts. Conse<uentl6, the6 cannot hear $ust co)pensation cases $ust
because the lands sub$ect of such cases happen to be *ithin their territorial $urisdiction.
Since R"C, /ranch 72 of Du)a%uete Cit6 is the desi%nated Special (%rarian Court for
the province of Ne%ros Oriental, it has $urisdiction over all cases for deter)ination of $ust
co)pensation involvin% a%ricultural lands *ithin that province, re%ardless of *hether or
not those properties are outside its re%ular territorial $urisdiction.
F9ERE.ORE, the Court :R(N"S the petitions, SE"S (SIDE the orders of the
Re%ional "rial Court, /ranch 72 of Du)a%uete Cit6 dated Septe)ber #7, 2334 and
October 73, 2334 in Civil Case 2334!#5#45, entitled +and /an0 of the Philippines v.
Cora1on Ville%as, and its orders dated Nove)ber #;, 2334 and Dece)ber #5, 2334 in
Civil Case 2334!#5#,7, entitled +and /an0 of the Philippines v. 9eirs of Catalino V.
Noel and Procula P. S6, *hich orders dis)issed the cases before it for lac0 of $urisdiction.
.urther, the Court DIREC"S the Re%ional "rial Court, /ranch 72 of Du)a%uete Cit6 to
i))ediatel6 hear and decide the t*o cases unless a co)pro)ise a%ree)ent has in the
)eanti)e been approved in the latter case.
SO ORDERED.
ROBERTO A. ABAD
(ssociate Custice
FE CONCGR@
ANTON"O T. CARP"O
(ssociate Custice
Chairperson, Second Division
ARTURO D. BR"ON
(ssociate Custice
MAR"ANO C. DEL CAST"LLO
(ssociate Custice
)OSE PORTUGAL PERE#
(ssociate Custice
C E R " I . I C ( " I O N
Pursuant to Section #7, (rticle VIII of the Constitution, I certif6 that the conclusions in
the above Decision had been reached in consultation before the case *as assi%ned to the
*riter of the opinion of the Court8s Division.
ANTON"O T. CARP"O
(ctin% Chief Custice
oo*&o*+,
#
Resolution dated (pril ,, 233- consolidatin% :.R. #-37-5 *ith :.R. #-3-,#.
2
Rollo &:.R. #-37-5', pp. 77!75.
7
Id. at 7DH rollo &:.R. #-3-,#', p. 75.
5
Civil Case 2334!#5#45 doc0eted as :.R. #-37-5H Civil Case 2334!#5#,7
doc0eted as :.R. #-3-,#.
D
Rollo &:.R. #-37-5', p. 44.
;
Id. at #25!#73H 5;7!542.
4
Manifestation, rollo &:.R. #-3-,#', pp. #2-!#2,.
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Spouses (tuel v. Spouses Valde1, 5D# Phil. ;7#, ;5# &2337'.
,
77# Phil. #343, #34D &#,,;'.