HRS. OF SANTOS V.

CA
Herman Rey Santos, who is now substituted by his heirs, obtained the subject land thru a
public auction. Santos then registered the deed of sale in the register of deeds, after Garcia
failed to exercise his right of redemption.
Private respondent filed a Petition for Injunction and Damages with an application for the
issuance of a preliminary injunction with the Department of Agrarian Reform Adjudication
Board (DARAB), praying that petitioner be enjoined from preventing private respondent from
gathering the mango fruits. Darab granted the petition.
Private respondent filed a Petition for Consignation before the Regional Trial Court of
Bulacan, in an apparent attempt to redeem his land. This petition was dismissed.
Meanwhile, one Pantaleon Antonio filed on May 18, 1992 a motion to intervene [5] with the
DARAB claiming that "he is affected in his rights and interests
private respondent filed a complaint for Annulment/Cancellation of Sale and Document,
Redemption with Damages and Preliminary Writ of Injunction against Herman Rey Santos.
Adjudication Board suspended the hearing on Pantaleon Antonios motion for intervention.
Intervenor Pantaleon Antonio filed with the DARAB a Motion to Withdraw Intervenors
deposited share.[8] The motion was granted and intervenor Pantaleon Antonio was allowed to
withdraw harvest proceeds. DARAB then recognized Pantaleon Antonio as the duly
constituted agricultural tenant of the subject land.
As appealed, the Court of Appeals affirmed the Orders of DARAB. Hence, this petition.
Issue: W/N PARAD has jurisdiction over the matters raised by the intervenor.
Held: No, PARAD has no jurisdiction.
Rule II, Section 1 of the Revised Rules of Procedure of the DARAB, provides:
Section 1. Primary, Original and Appellate Jurisdiction. The Agrarian Reform
Adjudication Board shall have primary jurisdiction, both original and appellate,
to determine and adjudicate all agrarian disputes, cases, controversies, and
matters or incidents involving the implementation of the Comprehensive
Agrarian Reform Program under Republic Act No. 6657, Executive Order Nos.
229, 228 and 129-A, Republic Act No. 3844 as amended by Republic Act No.
6389, P.D. No. 27 and other agrarian laws and their implementing rules and
regulations. (Italics supplied)
"Agrarian dispute" is defined under Section 3(d) of Republic Act No. 6657 (CARP Law), as:
(d) Agrarian Dispute refers to any controversy relating to tenurial
arrangements, whether leasehold, tenancy, stewardship or otherwise, over
lands devoted to agriculture, including disputes concerning farmworkers

associations or representation of persons in negotiating, fixing, maintaining,

changing or seeking to arrange terms or conditions of such tenurial
arrangements.
It includes any controversy relating to compensation of lands acquired under
this Act and other terms and conditions of transfer of ownership from
landowners to farmworkers, tenants and other agrarian reform beneficiaries,
whether the disputants stand in the proximate relation of farm operator and
beneficiary, landowner and tenant, or lessor and lessee.
Clearly, no agrarian dispute is involved in this case. Tenancy relationship is needed for
DARAB to have jurisdiction over the case.
Court held that the jurisdiction of the Department of Agrarian Reform is
limited to the following: a) adjudication of all matters involving
implementation of agrarian reform; b) resolution of agrarian conflicts and land
tenure related problems; and c) approval and disapproval of the conversion,
restructuring or readjustment of agricultural lands into residential,
commercial, industrial, and other non-agricultural uses.
Petitioners and private respondent have no tenurial, leasehold, or any agrarian relations
whatsoever that could have brought this controversy under the ambit of the agrarian reform
laws. Consequently, the DARAB has no jurisdiction over the controversy.
REPUBLIC OF THE PHILIPPINES vs. COURT OF APPEALS and ACIL CORPORATION,
Respondents. G.R. No. 122256
FACTS:
Private respondent Acil Corporation owned several hectares of land, which the government
took pursuant to the Comprehensive Agrarian Reform Law. Private respondents certificates
of title were cancelled and new ones were issued and distributed to farmer-beneficiaries. The
lands were valued by the Land Bank of the Philippines at P19,312.24 per hectare for the
riceland and P4,267.68 per hectare for brushland, or for a total of P439,105.39.
Private respondent rejected the governments offer, pointing out that nearby lands planted to
the same crops were valued at the higher price of P24,717.40 per hectare. The matter was
brought before the Provincial Agrarian Reform Adjudicator (PARAD) who, sustained the initial
valuation made by the LBP.
Private respondent then filed a Petition for Just Compensation in the Regional Trial Court
sitting as a Special Agrarian Court, praying that DAR be ordered to pay P24,717.40 per
hectare. However, the RTC dismissed its petition on the ground that private respondent
should have appealed to the Department of Agrarian Reform Adjudication Board (DARAB),
pursuant to the latters Revised Rules of Procedure, before recourse to it (the RTC) could be
had. In addition the RTC found that, in violation of the DARABs rules of procedure the petition
had been filed more than fifteen (15) days after notice of the decision of the PARAD.

Issue: WON in cases involving claims for just compensation under R.A. No. 6657 an appeal
from the decision of the provincial adjudicator to the DARAB must first be made before a
landowner can resort to the RTC.
Answer: The contention has no merit.
Reasoning: Section 50 of R.A. No. 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 Department of Environment and
Natural Resources. Sec 57 also provides that the Special Agrarian Court shall have
original and exclusive jurisdiction over all petitions for the determination of just
compensation to landowners.
The Special Agrarian Courts shall decide all appropriate cases under their special jurisdiction
within thirty (30) days from submission of the case for decision.
Thus, under the law, the Land Bank 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. Through notice sent to the landowner pursuant to 16(a) of R.A. No. 6657, the DAR
makes an offer. In case the landowner rejects the offer, a summary administrative
proceeding is held and afterward 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 the price fixed, he may bring the
matter to the RTC acting as Special Agrarian Court. This in essence is the procedure for the
determination of compensation cases under R.A. No. 6657.
LBP v. Martinez
Facts: DAR acquired hectares of land belonging to Respondent Martinez, pursuant to RA
6657 or CARL. LBP offered P1.9m as just compensation but the same was rejected by the
respondent (unjust and confiscatory). DARAB conducted summary administrative
proceedings for the preliminary determination of just compensation in accordance with
Section 16 (d) of the CARL. After the proceeding DARAB ordered LBP to pay P12m to
Martinez.
LBP then filed a petition for fixing just compensation before SAC. Respondent contend that
the orders, rulings and decision of DARAB become final after the lapse of 15 days, and
moved for dismissal of the petition being filed out of time. Petitioner opposed.
Meanwhile, respondent filed a motion for the issuance of writ of execution, which was
eventually granted. Motion for reconsideration was denied by PARAD and ordered the
issuance of writ of execution.
LBP moved to quash and while motion was yet unresolved, LBP instituted petition for
certiorari. The petition and motion was both dismissed due to forum shopping. They then
elevated the case and filed a motion for review on certiorari.

Issue: W/N the PARAD gravely abused his discretion when he issued a writ of execution
despite the pendency of LBP's petition for fixing of just compensation with the Special
Agrarian Court (SAC).
Held: No, PARAD did not gravely abused his discretion.
Court ruled that in this case that the agrarian reform adjudicator's decision on land valuation
attains finality after the lapse of the 15-day period stated in the DARAB Rules. The petition
for the fixing of just compensation should therefore, following the law and settled
jurisprudence, be filed with the SAC within the said period. This conclusion, as already
explained in the assailed decision, is based on the doctrines laid down in Philippine Veterans
Bank v. Court of Appeals

(The Court in that case stressed that the petition was not an appeal from the
adjudicator's final decision but an original action for the determination of just
compensation.) SUNTAY original action not an appeal for the determination of just
compensation.
The Court merely decided the issue of whether cases involving just compensation
should first be appealed to the DARAB before the landowner can resort to the SAC
under Section 57 of R.A. No. 6657.
To resolve the conflict in the rulings of the Court, we now declare herein, for the
guidance of the bench and the bar, that the better rule is that stated in Philippine
Veterans Bank, reiterated in Lubrica and in the August 14, 2007 Decision in this
case. Thus, while a petition for the fixing of just compensation with the SAC is not
an appeal from the agrarian reform adjudicator's decision but an original action, the
same has to be filed within the 15-day period stated in the DARAB Rules; otherwise,
the adjudicator's decision will attain finality.