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They cite 50 of RA 6657 1 and argue that the fixing of just compensation for
the taking of lands under RA 6657 is a matter involving the implementation
of agrarian reform within the contemplation of this provision.
16(f) of RA 6657, which provides that any party who disagrees to the
decision of the DAR may bring the matter to the court of proper jurisdiction for
final determination of just compensation, confirms their construction of 50.
DARAB Rules likewise provide that decisions of agrarian reform adjudicators
may only be appealed to the DARAB.
Issue: WON in cases involving claims for just compensation under RA 6657 an appeal from
the decision of PARAD to the DARAB must first be made before a landowner can resort to the
RTC
Held/Ratio: NO.
It is true that 50 of RA 6657 grants the DAR primary jurisdiction to determine and
adjudicate agrarian reform matters and exclusive original jurisdiction over all
matters involving the implementation of agrarian reform, except those falling under
the exclusive jurisdiction of the Department of Agriculture and the DENR.
It is also true, however that 57 of the same law provides that Special Agrarian
Courts, which are RTCs, are given original and exclusive jurisdiction over two
categories of cases:
o All petitions for the determination of just compensation to
landowners, and
o The prosecution of all criminal offenses under RA 6657
The provision of 50 must be construed in harmony with 57 by considering cases
involving the determination of just compensation and criminal cases for violations of
RA 6657 as excepted from the plenitude of power conferred on the DAR.
There is a reason for this distinction. DAR is an administrative agency which
cannot be granted jurisdiction over cases of eminent domain (for such are
takings under RA 6657) and over criminal cases.
o EPZA v. Duly and Sumulong v. Guerrero: The valuation of property in eminent
domain is essentially a judicial function which cannot be vested in
administrative agencies.
o Scotys Department Store v. Micaller : SC struck down a law granting the then
Court of Industrial Relations jurisdiction to try criminal cases for violations of
the Industrial Peace Act.
With regard to DARAB Rules only a statute can confer jurisdiction on courts and
administrative agencies; rules of procedure cannot.
o It is noteworthy that the New Rules of Procedure of the DARAB (adopted
on May 30, 1994) now provide that in the event a landowner is not
satisfied with a decision of an agrarian adjudicator, the landowner
can bring the matter directly to the RTC sitting as Special Agrarian
Court.
o This is an acknowledgment by the DARAB that the decision of just
compensation cases for the taking of lands under RA 6657 is a power vested
in the courts.
Thus, under the law:
o LBP is charged with the initial responsibility of determining the value of lands
placed under land reform and the compensation to be paid for their taking.
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50. Quasi-Judicial Powers of the DAR. The DAR is hereby vested with primary jurisdiction to determine and
adjudicate agrarian reform matters and shall have exclusive original jurisdiction over all matters involving the
implementation of agrarian reform, except those falling under the exclusive jurisdiction of the Department of
Agriculture (DA) and the Department of Environment and Natural Resources (DENR)
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