Fact: Petitioner owned parcels of land in Tagum, Davao, which were taken by the Department of Agrarian Reform for distribution to landless farmers pursuant to the CARL. Dissatisfied with the valuation of the land made by respondents LBP and the DARAB, petitioner filed a petition for a determination of the just compensation for its property. The petition was filed with the RTC dismissed on the ground that it was filed beyond the 15-day reglementary period for filing appeals from the orders of the DARAB. On appeal to the Court of Appeals, the decision was affirmed.
Issue: Where DAR adjudicators have no jurisdiction to determine the just compensation for the taking of lands under the Comprehensive Agrarian Reform Program, because such jurisdiction is vested in Regional Trial Courts designated as Special Agrarian Courts.
Held: No, R.A. No. 6657, Sec. 50. provides that the DAR is hereby vested with primary jurisdiction to determine and adjudicate agrarian reform 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). 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 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.