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Prof. Joselito Guianan Chan's The Labor Code of the Philippines, Annotated Labor Standards & Social Legislation Volume I of a 3-Volume Series 2019 Edition (3rd Revised Edition)
 

 
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UNITED STATES SUPREME COURT JURISPRUDENCE
 

 
PHILIPPINE SUPREME COURT JURISPRUDENCE
 

   
January-2000 Jurisprudence                 

  • G.R. No. 123951 January 10, 2000 - ROMEO RANOLA, ET AL. v. COURT OF APPEALS, ET AL.

  • A.M. No. P-00-1360 January 18, 2000 - ELISEO SOREÑO v. RHODERICK MAXINO, ET AL.

  • G.R. No. 114683 January 18, 2000 - JESUS C. OCAMPO v. OFFICE OF THE OMBUDSMAN, ET AL.

  • G.R. Nos. 118441-42 January 18, 2000 - ARMANDO JOSE, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 119594 January 18, 2000 - PEOPLE OF THE PHIL. v. BENZON ONG

  • G.R. No. 125994 January 18, 2000 - PEOPLE OF THE PHIL. v. BENJAMIN ANDALES

  • G.R. No. 127135 January 18, 2000 - EASTERN ASSURANCE AND SURETY CORP. (EASCO) v. COURT OF APPEALS, ET AL.

  • G.R. No. 129846 January 18, 2000 - REPUBLIC OF THE PHIL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 130944 January 18, 2000 - PEOPLE OF THE PHIL. v. VICENTE ALIB, ET AL.

  • G.R. No. 131675 January 18, 2000 - PEDRO C. LAMEYRA v. GEORGE S. PANGILINAN

  • G.R. No. 132378 January 18, 2000 - ROGELIO JUAN v. PEOPLE OF THE PHIL.

  • G.R. No. 132767 January 18, 2000 - PHIL. VETERANS BANK v. COURT OF APPEALS, ET AL.

  • G.R. No. 134854 January 18, 2000 - FELIZARDO S. OBANDO, ET AL. v. EDUARDO F. FIGUERAS, ET AL.

  • G.R. No. 139465 January 18, 2000 - SECRETARY OF JUSTICE v. RALPH C. LANTION, ET AL.

  • A.M. No. MTJ-00-1245 January 19, 2000 - ANTONIO YU-ASENSI v. FRANCISCO D. VILLANUEVA

  • A.M. No. MTJ-97-1129 January 19, 2000 - FLAVIANO B. CORTES v. FELINO BANGALAN

  • A.M. No. RTJ-99-1513 January 19, 2000 - ALFREDO B. ENOJAS v. EUSTAQUIO Z. GACOTT

  • G.R. No. 107320 January 19, 2000 - A’ PRIME SECURITY SERVICES v. NLRC, ET AL.

  • G.R. Nos. 113666-68 January 19, 2000 - GOLDEN DONUTS, INC. v. NLRC, ET AL.

  • G.R. No. 114761 January 19, 2000 - ALEMAR’S SIBAL & SONS v. NLRC, ET AL.

  • G.R. No. 119217 January 19, 2000 - PEOPLE OF THE PHIL. v. MIGUEL S. LUCBAN

  • G.R. No. 122104 January 19, 2000 - PEOPLE OF THE PHIL. v. PEPITO ORBITA, ET AL.

  • G.R. Nos. 122297-98 January 19, 2000 - CRESCENTE Y. LLORENTE v. SANDIGANBAYAN, ET AL.

  • G.R. No. 122739 January 19, 2000 - PEOPLE OF THE PHIL. v. JOSE M. PANTORILLA, ET AL.

  • G.R. No. 123655 January 19, 2000 - ANGEL BAUTISTA v. COURT OF APPEALS, ET AL.

  • G.R. No. 123183 January 19, 2000 - PEOPLE OF THE PHIL. v. RUBEN SISON

  • G.R. No. 126516 January 19, 2000 - PEOPLE OF THE PHIL. v. SHIRLEY ALAO

  • G.R. No. 127572 January 19, 2000 - PEOPLE OF THE PHIL. v. SALVADOR VILLAR

  • G.R. No. 129072 January 19, 2000 - PEOPLE OF THE PHIL. v. ANTONIO ABUBU

  • G.R. No. 130957 January 19, 2000 - VH MANUFACTURING v. NLRC, ET AL.

  • G.R. No. 132152 January 19, 2000 - PEOPLE OF THE PHIL. v. EUGENIO ADRALES, ET AL.

  • G.R. No. 132248 January 19, 2000 - ERLINDA C. PEFIANCO v. MARIA LUISA C. MORAL

  • G.R. No. 132657 January 19, 2000 - WILLIAM DIU, ET AL. v. DOMINADOR IBAJAN, ET AL.

  • G.R. Nos. 132779-82 January 19, 2000 - PEOPLE OF THE PHIL. v. DONATO BERNALDEZ

  • G.R. No. 134003 January 19, 2000 - PEOPLE OF THE PHIL. v. ALBERT NAGUM

  • G.R. No. 134329 January 19, 2000 - VERONA PADA-KILARIO, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 134535 January 19, 2000 - PEOPLE OF THE PHIL. v. ALEJANDRO MAGNO, ET AL.

  • G.R. No. 137560 January 19, 2000 - MARIA G. CRUZ, ET AL. v. COURT OF APPEALS, ET AL.

  • A.C. No. 4749 January 20, 2000 - SOLIMAN M. SANTOS, JR. v. FRANCISCO R. LLAMAS

  • Adm. Matter No. MTJ-00-1241 January 20, 2000 - NAPOLEON S. VALENZUELA v. REYNALDO B. BELLOSILLO

  • A.M. No. MTJ-00-1242 January 20, 2000 - DANIEL DUMO, ET AL. v. ROMEO V. PEREZ

  • A.M. No. RTJ-00-1522 January 20, 2000 - ROMULO SJ TOLENTINO v. POLICARPIO S. CAMANO

  • G.R. No. 76371 January 20, 2000 - MARIANO TURQUESA, ET AL. v. ROSARIO VALERA, ET AL.

  • G.R. No. 87134 January 20, 2000 - PHIL. REGISTERED ELECTRICAL PRACTITIONERS, ET AL. v. JULIO FRANCA, ET AL.

  • G.R. Nos. 100718-19 January 20, 2000 - PEOPLE OF THE PHIL. v. FREDDIE JUAN, ET AL.

  • G.R. No. 106282 January 20, 2000 - PEOPLE OF THE PHIL. v. QUINCIANO RENDOQUE, ET AL.

  • G.R. No. 108067 January 20, 2000 - CYANAMID PHIL., INC. v. COURT OF APPEALS, ET AL.

  • G.R. No. 109376 January 20, 2000 - PANFILO O. DOMINGO v. SANDIGANBAYAN, ET AL.

  • G.R. No. 110807 January 20, 2000 - PEOPLE OF THE PHIL. v. REYNALD T. NARVASA

  • G.R. No. 110929 January 20, 2000 - ABELARDO LOPEZ, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 119652 & A.M. No. P-00-1358 January 20, 2000 - VENTURA O. DUCAT v. COURT OF APPEALS, ET AL.

  • G.R. No. 123860 January 20, 2000 - PEOPLE OF THE PHIL. v. EDWIN NAAG, ET AL.

  • G.R. No. 125451 January 20, 2000 - MARCIANA MUÑOZ v. COURT OF APPEALS, ET AL.

  • G.R. No. 126151 January 20, 2000 - MANILA INTERNATIONAL AIRPORT AUTHORITY, ET AL. v. SERGIO D. MABUNAY, ET AL.

  • G.R. No. 128887 January 20, 2000 - PEOPLE OF THE PHILS. v. EDGARDO AQUINO

  • G.R. No. 130713 January 20, 2000 - PEOPLE OF THE PHIL. v. GABRIEL FLORES

  • G.R. No. 130986 January 20, 2000 - PEOPLE OF THE PHIL. v. VICTOR PAILANCO

  • G.R. No. 131512 January 20, 2000 - LAND TRANSPORTATION OFFICE [LTO] v. CITY OF BUTUAN

  • G.R. No. 132368 January 20, 2000 - PEOPLE OF THE PHIL. v. PACITO GARCES, JR.

  • G.R. No. 133775 January 20, 2000 - FIDEL DABUCO, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. Nos. 131894-98 January 20, 2000 - PEOPLE OF THE PHILS. v. JESUS DOCENA

  • G.R. No. 134167 January 20, 2000 - NASSER IMMAM v. COMELEC, ET AL.

  • G.R. No. 125965 January 21, 2000 - PEOPLE OF THE PHIL. v. PATRICIO GOZANO

  • G.R. No. 133477 January 21, 2000 - PEOPLE OF THE PHIL. v. BENJAMIN RAFALES

  • G.R. No. 135904 January 21, 2000 - PEOPLE OF THE PHIL. v. ALVIN TAN

  • G.R. Nos. 89591-96 January 24, 2000 - PEOPLE OF THE PHIL. v. BONIFACIO SANZ MACEDA

  • G.R. No. 100518 January 24, 2000 - ASSOCIATION OF TRADE UNIONS (ATU), ET AL. v. OSCAR N. ABELLA, ET AL.

  • G.R. No. 101932 January 24, 2000 - FRANCISCO H. ESCAÑO, JR., ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 111285 January 24, 2000 - PEOPLE OF THE PHIL. v. VICENTE VALLA

  • G.R. No. 116066 January 24, 2000 - NUEVA ECIJA I ELECTRIC COOPERATIVE, ET AL. v. NLRC, ET AL.

  • G.R. No. 124715 January 24, 2000 - RUFINA LUY LIM v. COURT OF APPEALS, ET AL.

  • G.R. No. 125031 January 24, 2000 - PERMEX INC., ET AL. v. NLRC, ET AL.

  • G.R. No. 129693 January 24, 2000 - PEOPLE OF THE PHIL. v. RUDY CORTES

  • A.M. No. RTJ-00-1525 January 25, 2000 - MARTIN D. PANTALEON v. TEOFILO L. GUADIZ, JR.

  • G.R. No. 80129 January 25, 2000 - GERARDO RUPA, SR. v. COURT OF APPEALS, ET AL

  • G.R. No. 102706 January 25, 2000 - PEOPLE OF THE PHIL. v. LEON LUMILAN, ET AL.

  • G.R. No. 107427 January 25, 2000 - JAMES R. BRACEWELL v. COURT OF APPEALS, ET AL.

  • G.R. No. 113518 January 25, 2000 - PEOPLE OF THE PHIL. v. ESTEBAN ARLEE

  • G.R. No. 113684 January 25, 2000 - PEOPLE OF THE PHIL. v. ARMANDO GALLARDO, ET AL.

  • G.R. No. 116332 January 25, 2000 - BAYNE ADJUSTERS AND SURVEYORS v. COURT OF APPEALS, ET AL.

  • G.R. No. 119595 January 25, 2000 - PEOPLE OF THE PHIL. v. JOVITO BARONA, ET AL.

  • G.R. No. 120267 January 25, 2000 - CLARA ESPIRITU BORLONGAN, ET AL. v. CONSUELO MADRIDEO, ET AL.

  • G.R. No. 121439 January 25, 2000 - AKLAN ELECTRIC COOPERATIVE INCORPORATED (AKELCO) v. NLRC, ET AL.

  • G.R. No. 129246 January 25, 2000 - GREENFIELD REALTY CORP., ET AL. v. LORETO CARDAMA, ET AL.

  • G.R. Nos. 131633-34 January 25, 2000 - PEOPLE OF THE PHIL. v. CRESENCIANO ENOLVA

  • G.R. No. 133132 January 25, 2000 - ALEXIS C. CANONIZADO, ET AL. v. ALEXANDER P. AGUIRRE, ET AL.

  • G.R. No. 135874 January 25, 2000 - SECURITY BANK CORPORATION v. COURT OF APPEALS, ET AL.

  • A.M. No. 99-12-192-MTC January 26, 2000 - HOLD DEPARTURE ORDER ISSUED BY ACTING JUDGE ANICETO L. MADRONIO

  • A.M. No. RTJ-00-1524 January 26, 2000 - LUCIA F. LAYOLA v. BASILIO R. GABO, JR.

  • G.R. No. 107395 January 26, 2000 - TOURIST DUTY FREE SHOPS v. SANDIGANBAYAN, ET AL.

  • G.R. No. 126115 January 26, 2000 - PEOPLE OF THE PHIL. v. ALFONSO BALGOS

  • G.R. No. 131374 January 26, 2000 - ABBOTT LABORATORIES PHIL. v. ABBOTT LABORATORIES EMPLOYEES UNION, ET AL.

  • G.R. No. 133842 January 26, 2000 - FEDERICO S. SANDOVAL v. COMELEC, ET AL.

  • G.R. No. 133969 January 26, 2000 - NEMESIO GARCIA v. NICOLAS JOMOUAD, ET AL.

  • G.R. Nos. 102961-62, 107625 & 108759 January 27, 2000 - JESUS P. LIAO v. COURT OF APPEALS, ET AL.

  • G.R. No. 117040 January 27, 2000 - RUBEN SERRANO v. NLRC, ET AL.

  • G.R. No. 130843 January 27, 2000 - PEOPLE OF THE PHIL. v. ZOILO BORROMEO

  • Adm. Case No. 1474 January 28, 2000 - CRISTINO G. CALUB v. ABRAHAM SULLER

  • A.M. No. MTJ-00-1246 January 28, 2000 - HEIRS OF JUAN and NATIVIDAD GERMINANDA v. RICARDO SALVANERA

  • A.M. No. MTJ-99-1211 January 28, 2000 - ZENAIDA S. BESO v. JUAN DAGUMAN

  • A.M. No. P-93-985 January 28, 2000 - MARTA BUCATCAT v. EDGAR BUCATCAT, ET AL.

  • G.R. No. 112177 January 28, 2000 - PEOPLE OF THE PHIL. v. TITO ZUELA, ET AL.

  • G.R. No. 112329 January 28, 2000 - VIRGINIA A. PEREZ v. COURT OF APPEALS, ET AL.

  • G.R. No. 115824 January 28, 2000 - RAFAEL M. ALUNAN III, ET AL. v. MAXIMIANO C. ASUNCION, ET AL.

  • G.R. No. 125279 January 28, 2000 - PEOPLE OF THE PHIL. v. JESUS TANAIL

  • G.R. No. 124129 January 28, 2000 - PEOPLE OF THE PHIL. v. DOMINGO BRIGILDO

  • G.R. Nos. 124384-86 January 28, 2000 - PEOPLE OF THE PHIL. v. ROMENCIANO "OMENG" RICAFRANCA, ET AL.

  • G.R. No. 125671 January 28, 2000 - CONDO SUITE CLUB TRAVEL v. NLRC, ET AL.

  • G.R. No. 125865 January 28, 2000 - JEFFREY LIANG (HUEFENG) v. PEOPLE OF THE PHIL.

  • G.R. No. 126802 January 28, 2000 - ROBERTO G. ALARCON v. COURT OF APPEALS, ET AL.

  • G.R. No. 127568 January 28, 2000 - PEOPLE OF THE PHIL. v. ROLANDO BACULE

  • G.R. Nos. 129756-58 January 28, 2000 - PEOPLE OF THE PHIL. v. JULIAN DEEN ESCAÑO, ET AL.

  • G.R. No. 131520 January 28, 2000 - ESTELITA AGUIRRE v. COURT OF APPEALS, ET AL.

  • G.R. No. 131778 January 28, 2000 - HERMAN TIU LAUREL v. PRESIDING JUDGE, ET AL.

  • G.R. No. 132138 January 28, 2000 - PEOPLE OF THE PHILS. v. ROMEO LLAMO

  • G.R. No. 133486 January 28, 2000 - ABS-CBN BROADCASTING CORP. v. COMELEC

  • G.R. No. 133987 January 28, 2000 - PEOPLE OF THE PHIL. v. JOHNNY BARTOLOME

  • G.R. No. 136805 January 28, 2000 - DIESEL CONSTRUCTION COMPANY INC. v. JOLLIBEE FOODS CORP.

  • G.R. No. 137537 January 28, 2000 - SMI DEVT. CORP. v. REPUBLIC OF THE PHIL.

  • G.R. No. 137718 January 28, 2000 - REYNALDO O. MALONZO, ET AL. v. RONALDO B. ZAMORA, ET AL.

  • G.R. No. 139545 January 28, 2000 - MAIMONA H. N. M. S. DIANGKA v. COMELEC, ET AL.

  • A.M. No. MTJ-99-1226 January 31, 2000 - GLORIA LUCAS v. AMELIA A. FABROS

  • G.R. Nos. 88521-22 & 89366-67 January 31, 2000 - HEIRS OF EULALIO RAGUA v. COURT OF APPEALS, ET AL.

  • G.R. No. 105827 January 31, 2000 - J.L. BERNARDO CONSTRUCTION v. COURT OF APPEALS, ET AL.

  • G.R. No. 112139 January 31, 2000 - LAPANDAY AGRICULTURAL DEVT. CORP. v. COURT OF APPEALS, ET AL.

  • G.R. No. 115045 January 31, 2000 - UNIVERSITY PHYSICIANS SERVICES v. COURT OF APPEALS, ET AL.

  • G.R. No. 116729 January 31, 2000 - PEOPLE OF THE PHIL. v. MARLON LERIO

  • G.R. No. 120706 January 31, 2000 - RODRIGO CONCEPCION v. COURT OF APPEALS, ET AL.

  • G.R. No. 123094 January 31, 2000 - PEOPLE OF THE PHIL. v. LUISITO PAGLINAWAN

  • G.R. No. 125440 January 31, 2000 - GENERAL BANK AND TRUST CO., ET AL. v. OMBUDSMAN, ET AL.

  • G.R. No. 127797 January 31, 2000 - ALEJANDRO MILLENA v. COURT OF APPEALS, ET AL.

  • G.R. No. 128536 January 31, 2000 - ROQUE G. GALANG v. COURT OF APPEALS, ET AL.

  • G.R. No. 128607 January 31, 2000 - ALFREDO MALLARI SR., ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 129071 January 31, 2000 - PEOPLE OF THE PHIL. v. ROBERTO MILLIAM, ET AL.

  • G.R. Nos. 129505 & 133359 January 31, 2000 - OCTAVIO S. MALOLES II v. PACITA DE LOS REYES PHILLIPS

  • G.R. No. 130104 January 31, 2000 - ELIZABETH SUBLAY v. NLRC, ET AL.

  • G.R. No. 130666 January 31, 2000 - PEOPLE OF THE PHIL. v. CASIMIRO JOSE

  • G.R. No. 134437 January 31, 2000 - NATIONAL STEEL CORP. v. COURT OF APPEALS, ET AL.

  • G.R. No. 139758 January 31, 2000 - LUCIEN TRAN VAN NGHIA v. RUFUS B. RODRIGUEZ, ET AL.

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    G.R. No. 101932   January 24, 2000 - FRANCISCO H. ESCAÑO, JR., ET AL. v. COURT OF APPEALS, ET AL.

     
    PHILIPPINE SUPREME COURT DECISIONS

    SECOND DIVISION

    [G.R. No. 101932. January 24, 2000.]

    FRANCISCO H. ESCAÑO, JR. and LYDIA T. ESCAÑO, Petitioners, v. COURT OF APPEALS and LAND BANK OF THE PHILIPPINES, Respondents.

    D E C I S I O N


    QUISUMBING, J.:


    This petition for review on certiorari seeks: (1) to set aside the decision of respondent Court of Appeals in CA G.R. SP 24585, promulgated on July 18, 1991; (2) to set aside its resolution dated September 11, 1991; and (3) to order the Special Agrarian Court of Bohol to continue hearing Civil Case 4644.

    Petitioners owned 63.6226 hectares of agricultural land in Vallehermoso, Carmen, Bohol. They offered 59.6237 hectares of the land to the government through the Department of Agrarian Reform (DAR) pursuant to E.O. No. 229. DAR twice fixed the value, which petitioners also twice rejected for being much lower than the actual fair value. After the second rejection, DAR stopped communicating with petitioners. Petitioners claimed that during the hiatus, farm production fell by 80% because the farmers were allegedly advised by Provincial Agrarian Reform Officers (PARO) to deliberately reduce their production to depress the land value.chanrobles.com : virtual law library

    On November 29, 1989, petitioners filed a petition for just compensation, docketed as Civil Case No. 4644, in the Special Agrarian Court in Bohol. On April 10, 1990, respondent Land Bank filed a motion to dismiss on two grounds: (1) that the plaintiffs had not exhausted administrative remedies and (2) that plaintiffs were not the real parties in interest, but were merely lessees and not the registered owners. The land, according to the Land Bank was owned by the Development Bank of the Philippines. But the motion to dismiss was denied, upon a showing of a Confirmation of the Deed of Sale executed August 25, 1989 by the DBP in favor of petitioners.

    Thereafter, pre-trial conferences were held. On October 31, 1990, Presiding Judge Pacito Yape issued a Pre-Trial Order, and with the concurrence of the parties, the legal issue was limited to the question of the amount of just compensation. Respondents were ordered to file responsive pleadings. 1

    Meanwhile, on June 14, 1990, President Corazon C. Aquino issued E.O. No. 405, which vested on the Land Bank primary responsibility to determine land valuation and the compensation for all private lands suitable for agriculture under either the Voluntary Offer to Sell (VOS) or Compulsory Acquisition (CA) arrangement as governed by Republic Act 6657, known as the "Comprehensive Agrarian Reform Law of 1988." 2

    On December 5, 1990, Land Bank moved to suspend proceedings or dismiss the Escaños’ petition. It reiterated the two aforecited grounds stated in their April 10, 1990 motion to dismiss. Additionally, Land Bank explained that as a land reform matter, the case falls within the primary jurisdiction of the DAR; that valuation by the PARO was not the final determination since it still was subject to the final determination of the Department of Agrarian Reform Adjudication Board (DARAB), which had original and appellate jurisdiction; and that since the matter had not passed through all the required stages, there was no exhaustion of administrative remedies, hence, no cause of action.

    On January 16, 1991, the lower court issued another order, denying Land Bank’s second motion to suspend proceedings and/or dismiss despite the latter’s added ground that it had not been given the opportunity to exercise its legal mandate to determine the land valuation. The lower court found that the Land Bank had been given sufficient opportunity to sit down with petitioners to arrive at a true and proper valuation. 3

    On April 2, 1991, Land Bank filed its petition before the Court of Appeals. It claimed that the lower court issued the orders dated August 17, 1990, January 16 and January 18, 1991 without jurisdiction, or with grave abuse of discretion, amounting to lack or excess of jurisdiction.chanrobles.com : red

    In resolving the issue of jurisdiction in the determination of land valuation and compensation, the appellate court granted Land Bank’s petition. It disposed as follows:jgc:chanrobles.com.ph

    "WHEREFORE, the petition is hereby granted and the Orders dated August 17, 1990, January 16, 18 and February 18, 1991 are set aside. Further, the petition before the Special Agrarian Court is hereby ordered dismissed." 4

    The appellate court, accepted the argument that the effectivity of the Revised Rules of Procedure of R.A. 6657 was earlier than the date when the Escaños filed their petition to fix just compensation before the Special Agrarian Court on December 14, 1989. Said Revised Rules took effect on December 26, 1988. According to the Court of Appeals, the lower court could not "feign" jurisdiction because Section 1, Rule XVII of the Transitory Provisions of the Revised Rules states:jgc:chanrobles.com.ph

    "SECTION 1. Transitory Provisions. — All agrarian cases pending before the regular courts of law at the time of the effectivity of these Rules shall remain with such courts until their final termination.

    Cases pending in the Office of the Secretary of Agrarian Reform before the effectivity of these Rules may be decided and finally disposed of thereat in accordance with the principle of continuing jurisdiction. The Secretary, however, may, in his discretion sort out said cases and refer the justiciable and adversarial ones to the Adjudication Board for Section 1, Rule 11 hereof." 5

    The appellate court further explained that when an administrative agency promulgates rules and regulations it "makes" a new law with the force and effect of a valid law. It added that the Supreme Court in Association of Small Landowners v. Secretary of Agrarian Reform, 175 SCRA 343, had emphasized the indispensable role of the Department of Agrarian Reform and the Land Bank in fixing preliminary valuation.chanroblesvirtuallawlibrary

    Now before us, petitioners assert that the Court of Appeals erred:chanrob1es virtual 1aw library

    I


    IN HOLDING THE SPECIAL AGRARIAN COURT OF BOHOL WITHOUT JURISDICTION FROM THE BEGINNING TO ENTERTAIN CIVIL CASE NO. 4644 WHICH CIVIL CASE IS FOR DETERMINATION OF JUST COMPENSATION;

    II


    IN HOLDING THAT SECTION 59 OF R.A. 6657 IS NOT A BAR TO THE PETITION FOR CERTIORARI (CA-G.R. S.P. 24585) INSTITUTED BEFORE IT BY PRIVATE RESPONDENT WHILE CIVIL CASE NO. 4644 REMAINS PENDING BEFORE THE SPECIAL AGRARIAN COURT;

    III


    IN HOLDING THAT E.O. 405 HAS TO BE COMPLIED WITH BEFORE THE FILING OF CIVIL CASE NO. 4644, NOTWITHSTANDING THE FACT THAT CIVIL CASE NO. 4644 WAS FILED BEFORE THE ISSUANCE OF E.O. 405 AND IN HOLDING FURTHER THAT FAILURE TO SO COMPLY IS A GROUND FOR THE DISMISSAL OF CIVIL CASE NO. 4644;

    IV


    IN HOLDING THAT PRIVATE RESPONDENT LBP IS AN INSTRUMENTALITY OF STATE AND AS SUCH IS EXEMPT FROM THE EFFECTS OF ESTOPPEL;

    V


    IN PASSING UPON ISSUES NOT RAISED IN THE PETITION THEREBY DENYING PETITIONERS THE OPPORTUNITY TO TRAVERSE AND CONTROVERT THEM.

    Of these assigned errors, let us focus on the first three, jointly.chanrobles virtuallawlibrary

    Recall that on May 30, 1994, the Department of Agrarian Reform Adjudication Board (DARAB) adopted its new Rules of Procedure. Rule 13 Sec. 11 clearly states that in the event that a landowner is not satisfied with a decision of an agrarian adjudicator, the landowner could bring the matter directly to the Regional Trial Court sitting as Special Agrarian Court. Thus, DARAB recognized that jurisdiction on just compensation cases for the taking of lands under R.A. No. 6657 is vested in the courts. 6

    In Republic v. Court of Appeals, we held:jgc:chanrobles.com.ph

    ". . . Special Agrarian Courts which are Regional Trial Courts, are given original and exclusive jurisdiction over two categories of cases, to wit: (1) ‘all petitions for the determination of just compensation to landowners’ and (2) ‘the prosecution of all criminal offenses under [R.A. No. 6657].’ The provision of Section 50 must be construed in harmony with this provision by considering cases involving the determination of just compensation and criminal cases for violations of R.A. No. 6657 as excepted from the plenitude of power conferred on the DAR. Indeed, there is reason for this distinction. The DAR is an administrative agency which cannot be granted jurisdiction over cases of eminent domain (for such are taking under R.A. No. 6657) and over criminal cases. Thus, in EPZA v. Dulay and Sumulong v. Guerrero we held that the valuation of property in eminent domain is essentially a judicial function which cannot be vested in administrative agencies, while in Scoty’s Department Store v. Micaller we struck down a law granting the then Court of Industrial Relations jurisdiction to try criminal cases for violations of the Industrial Peace Act.

    x       x       x


    . . . It would subvert the "original and exclusive" jurisdiction of the RTC [Regional Trial Court] for the Department of Agrarian Reform to vest original jurisdiction in compensation cases in administrative officials and make the RTC an appellate court for the review of administrative decisions.

    x       x       x


    What [agrarian] adjudicators are empowered to do is only to determine in a preliminary manner the reasonable compensation to be paid to landowners, leaving to the courts the ultimate power to decide the question." 7

    E.O. No. 405, issued June 14, 1990, vested in the Land Bank the initial responsibility of determining the value of lands placed under land reform and the compensation for their taking. Thereafter, in notices sent to the landowner, the DAR makes an appropriate offer to buy the land. If the landowner rejects the offer, a summary administrative proceeding is held and afterwards the Provincial (PARAD), the Regional (RARAD) or the central (DARAB) adjudicator as the case may be, depending on the value of the land, fixes the price to be paid for the land. If the landowner does not agree to said price, he may bring the matter before the RTC acting as a Special Agrarian Court. 8

    Recalling the steps taken by petitioners as earlier discussed, vis-a-vis the procedural rules, it is our view that petitioners had complied with the procedural requirements up to its filing of the petition for just compensation before the regional trial court.chanrobles.com.ph:red

    The Land Bank now avers that on December 19, 1989, a Notice of Acquisition signed by the DAR Secretary was issued to petitioners offering a higher value of P480,137.81 for 63.6226 hectares. It allegedly gave petitioners time to reply, and for DAR to conduct summary administrative proceedings wherein petitioners, the Land Bank, and other parties were requested to submit evidence on what should be the just compensation to be paid for petitioners’ land. The summary administrative proceedings, however, did not take place allegedly because petitioners by then had filed Civil Case No. 4644 in the Special Agrarian Court in Bohol on November 29, 1989. 9

    Land Bank further claims it had not been given the opportunity to exercise its legal mandate to fix just compensation under the land reform law, as mandated by E.O. No. 405, pursuant to R.A. 6657, Sections 17 and 18. R.A. 6657 took effect June 15, 1988, earlier than the filing of Civil Case No. 4644, according to the Land Bank. Thus it argues that, on the basis of guidelines provided under Administrative Order No. 17, series of 1989, even before E.O. No. 405, the proper procedure was for DAR to make its own valuation of the land and for the Land Bank to also conduct a separate valuation. Both would compare their valuation and if necessary both would agree to a common valuation. The case would then be "ripe for summary proceedings." Land Bank in its Comment before us sums up developments below as follows:jgc:chanrobles.com.ph

    "On April 3, 1988, petitioners filed with the Department of Agrarian Reform (DAR), a voluntary offer to sell (VOS) of the 59.6237 hectares of the questioned land; the smaller portion of about (6) hectares having been already covered by the operation land transfer (OLT) under P.D. 27. After the usual processing by the DAR, including an ocular inspection of the questioned land, on March 20, 1989, the Provincial Agrarian Reform Office (PARO) initially computed the value of the said land at P345,343.52 pursuant to Section 6 of E.O. No. 229. Petitioners rejected the said valuation.

    "On July 20, 1989, the PARO made another preliminary computation of the value of the said land under Sections 17, and 18 of R.A. 6657, for a higher amount of P429,938.15. Again, petitioners rejected the valuation.

    "On December 19, 1989, a Notice of Acquisition . . . was issued to petitioners offering a higher value of P480,137.81. . . .

    "But the summary administrative proceedings stated in the said Notice of Acquisition did not take place because Petitioners had by then in haste, already filed the case for just compensation with the court a quo." 10

    Land Bank was apparently not notified nor consulted by the DAR in fixing the amount of land value in their first and second offers to the Escaños. Petitioners counter that a second valuation offer could not have been made if summary proceedings were not conducted. The Notice of Acquisition was sent to petitioners, five months after DAR’s second offer on July 20, 1989, which petitioners had rejected. Was this Notice an afterthought designed to show that summary proceedings had not yet been done? Or was it issued to remedy the inter-agency oversight concerning Land Bank’s non-participation? Whatever the reason might be, it is established fact that the Notice was sent to petitioners only after they had filed their petition for just compensation before the Special Agrarian Court in Bohol.chanrobles.com : law library

    By that time, this special court had already acquired jurisdiction over the controversy. Land Bank had no basis to insist on dismissing or suspending the proceedings before said court so it could first exercise its mandate to participate in fixing the land valuation. But nothing prevents the Land Bank from participating in judicial proceedings therein. In fact, in its Pre-Trial Order dated October 31, 1990, the lower court rightly ordered the herein respondents to submit responsive pleadings. Note, however, that in its Order dated August 17, 1990 said court observed that the proper administrative officials were already given the opportunity to act upon the petitioners’ case but failed to do so for quite sometime, so that there was unreasonable delay or official inaction. 11

    Having decided the principal issue, that jurisdiction properly belongs to the Special Agrarian Court, the remaining assigned errors need not now delay us. Suffice it to declare now that respondent Court of Appeals committed reversible errors of law in issuing its assailed decision and resolution. Hence, both have to be set aside.

    WHEREFORE, the petition is GRANTED. The Decision of the Court of Appeals dated July 18, 1991 in CA GR S.P. No. 24585 entitled "Land Bank of the Philippines v. Hon. Pacito A. Yape and Sps. Francisco and Lydia Escaño," is REVERSED and SET ASIDE. Its Order dated September 11, 1991 is likewise SET ASIDE. The Special Agrarian Court is hereby ORDERED to continue hearing Civil Case No. 4644 without further delay.

    No pronouncement as to costs.chanrobles.com : chanrobles.com.ph

    SO ORDERED.

    Bellosillo, Mendoza, Buena and De Leon, Jr., JJ., concur.

    Endnotes:



    1. Rollo, p. 56.

    2. Sec. 1, E.O. No. 405.

    3. Rollo, pp. 77-78.

    4. Id. at 110.

    5. Revised Rules of Procedure, Department of Agrarian Reform Adjudication Board, December 26, 1988.

    6. Republic v. Court of Appeals, Et Al., 263 SCRA 758, 764 (1996).

    7. Id. at 763.

    8. Id. at 765. Citing Vinzons-Magana v. Estrella, 201 SCRA 536 (1991); Association of Small Landowners in the Philippines, Inc. v. Secretary of Agrarian Reform, 175 SCRA 343, 382 (1989).

    9. Rollo, p. 126.

    10. Id. at 126-127.

    11. Id. at 56.

    G.R. No. 101932   January 24, 2000 - FRANCISCO H. ESCAÑO, JR., ET AL. v. COURT OF APPEALS, ET AL.


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