Professional Documents
Culture Documents
REMEDIAL LAW
LAND
BANK
OF
THE
PHILIPPINES v. LEONILA
CELADA
G.R.
No.
164876,
23
January
2006,
YnaresSantiago, J. (First Division)
The RTC, sitting as a SAC, has
original
and
exclusive
jurisdiction over all petitions
for the determination
of
just
compensation
to
landowners. This original and
exclusive jurisdiction of the
RTC would be undermined if
DAR
would
vest
in
administrative officials original
jurisdiction in compensation
cases and make the RTC an
appellate
court for the review of
administrative
decision.
Although the new rules speak
of directly appealing the
decision of
adjudicators to the RTCs
sitting as SACs, the original
and exclusive jurisdiction to
determine such cases is in the
RTCs.
Celada owns an agricultural
land, 60% of which was
recourse.
Meanwhile,
the
DARAB Provincial Adjudicator
affirmed the valuation made
by Land
Bank. Thereafter, the Special
Agrarian Court (SAC), where
Celadas petition was filed,
rendered
judgment fixing the value of
the land at P354,847.50,
finding that Celadas evidence
showed that the
neighboring lands of similar
classification were paid higher
than what was quoted by
Land Bank. It
denied
Land
Banks
affirmative defense. The Court
of Appeals dismissed Land
Banks appeal.
Land Bank maintains that the
SAC
erred
in
assuming
jurisdiction
over
Celadas
petition for
judicial determination of just
compensation
despite
the
pendency
of
the
administrative proceedings
before the DARAB. It also
contends that the SAC erred
in
fixing
the
just
compensation of the land
based on the valuation of
neighboring lands instead of
its actual land use.
ISSUES:
assumed
over
of
just
Case
Digest
on
PHIL.
VETERANS BANK V. CA
18 Jan. 2000
Facts:
Ps land was taken by DAR
pursuant
to the
Comprehensive
Agrarian
Reform Law. P contended that
DAR adjudicators have
no jurisdiction to determine
the just compensation for the
taking of lands under CARP
because such jurisdiction is
vested inthe RTC.
Issue:
Whether the DAR or RTC has
jurisdiction
Held:
Held:
LBP
vs.
Raymunda
Martinez,
(G.R.
No.
169008, July 31, 2008)
Issue:
Whether or not the Special
Agrarian Courts are considered
appellate courts in the
determination of just
compensation
Held:
No.
To implement the provisions of
R.A. No. 6657, particularly
Section 50 thereof, Rule XIII,
Section 11 of the DARAB Rules
of Procedure provides:
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
administrative action.
Accordingly, as the petition in the
Regional Trial Court was filed
beyond the 15-day period
provided in Rule XIII, 11 of the
Rules of Procedure of the
DARAB, the trial court correctly
dismissed the case and the Court
of Appeals correctly affirmed the
order of dismissal.
Issue:
Held: