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The government took private land pursuant to an agrarian reform law and offered compensation to the landowner. The landowner rejected the offer, arguing the valuation was too low. The case was brought to the Provincial Agrarian Reform Adjudicator and then the RTC, which dismissed it for failing to first go to the DAR Adjudication Board. The Court of Appeals reversed. The Supreme Court ruled that while DAR has primary jurisdiction over agrarian reform matters, Regional Trial Courts have original and exclusive jurisdiction over cases determining just compensation for lands taken. DAR adjudicators can make preliminary valuations but courts have the ultimate power to decide compensation amounts in eminent domain cases.
The government took private land pursuant to an agrarian reform law and offered compensation to the landowner. The landowner rejected the offer, arguing the valuation was too low. The case was brought to the Provincial Agrarian Reform Adjudicator and then the RTC, which dismissed it for failing to first go to the DAR Adjudication Board. The Court of Appeals reversed. The Supreme Court ruled that while DAR has primary jurisdiction over agrarian reform matters, Regional Trial Courts have original and exclusive jurisdiction over cases determining just compensation for lands taken. DAR adjudicators can make preliminary valuations but courts have the ultimate power to decide compensation amounts in eminent domain cases.
The government took private land pursuant to an agrarian reform law and offered compensation to the landowner. The landowner rejected the offer, arguing the valuation was too low. The case was brought to the Provincial Agrarian Reform Adjudicator and then the RTC, which dismissed it for failing to first go to the DAR Adjudication Board. The Court of Appeals reversed. The Supreme Court ruled that while DAR has primary jurisdiction over agrarian reform matters, Regional Trial Courts have original and exclusive jurisdiction over cases determining just compensation for lands taken. DAR adjudicators can make preliminary valuations but courts have the ultimate power to decide compensation amounts in eminent domain cases.
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.
Acme Finishing Co., Inc., A Corporation of The State of New York v. Robertson Brothers, Inc., A Corporation of The State of New Jersey and A. W. Robertson, 343 F.2d 801, 3rd Cir. (1965)
Walter Tantzen, Inc. and Insurance Company of North America v. Thomas Shaughnessy and Director, Office of Workers' Compensation Programs, United States Department of Labor, 624 F.2d 5, 2d Cir. (1980)