JUSTICE MARTIN VILLARAMA, JR.: EXPROPRIATION: THE POWER TO DECIDE JUST COMPENSATION CASES FOR THE TAKING OF LANDS UNDER R.A. NO. 6657 IS VESTED IN THE COURTS

In Philippine Veterans Bank v. Court of Appeals, G.R. No. 132767, January 18, 2000, 322 SCRA 139.), petitioner landowner who was dissatisfied with the valuation made by LBP and DARAB, filed a petition for determination of just compensation in the RTC (SAC).  However, the RTC dismissed the petition on the ground that it was filed beyond the 15-day reglementary period for filing appeals from the orders of the DARAB.  On appeal, the CA upheld the order of dismissal. When the case was elevated to the Supreme Court, it likewise affirmed the CA and declared that:

As we held in Republic v. Court of Appeals, this rule is an acknowledgment by the DARAB that the power to decide just compensation cases for the taking of lands under R.A. No. 6657 is vested in the courts.  It is error to think that, because of Rule XIII, §11, the original and exclusive jurisdiction given to the courts to decide petitions for determination of just compensation has thereby been transformed into an appellate jurisdiction.  It only means that, in accordance with settled principles of administrative law, primary jurisdiction is vested in the DAR as an administrative agency to determine in a preliminary manner the reasonable compensation to be paid for the lands taken under the Comprehensive Agrarian Reform Program, but such determination is subject to challenge in the courts.

           The jurisdiction of the Regional Trial Courts is not any less “original and exclusive” because the question is first passed upon by the DAR, as the judicial proceedings are not a continuation of the administrative determination.  For that matter, the law may provide that the decision of the DAR is final and unappealable.  Nevertheless, resort to the courts cannot be foreclosed on the theory that courts are the guarantors of the legality of the administrative action (Land Bank of the Phils. vs. Severino Listana, G.R. No. 168105, July 27, 2011, VILLARAMA, JR., J.).