Presiding ○ The decision became final and executory and
Judge, RTC, Misamis Oriental, Br. 40, Cagayan de Oro City Springfield continued with the development of the 6 February 2007 | Ponente: Austria-Martinez property. ● DAR Regional Director filed a petition for relied from Overview: A DARAB decision was appealed to the RTC for judgment of the DARAB decision annulment but the RTC dismissed the appeal for lack of ● 5 October 1995 – DARAB granted the petition jurisdiction. The Court held that the RTC has the power to annul ○ It directed the Municipal Agrarian Reform Office to judgments of inferior courts and quasi-judicial bodies of equal proceed with the documentation, acquisition, and ranking to such inferior courts but not those of courts and quasi- distribution of the property to the true and lawful judicial bodies of equal ranking to the RTC. beneficiaries. ● 22 May 1997 – DARAB ordered the heir of Piit and Statement of the Case Springfield o pay the farmer-beneficiaries P12,340,800.00 ● DARAB declared Springfield under the coverage of CARL corresponding to the value of the property since the and ordered it to pay the farmer-beneficiaries. property has already been developed into a subdivision. ● RTC dismissed the case for lack of jurisdiction ● 13 June 1997 - Springfield and the heirs of Piit filed with ● CA dismissed the action for lack of merit ruling that the the RTC of CDO a petition for annulment of the DARAB RTC does not have jurisdiction to annul the DARAB Decision dated October 5, 1995 and all its subsequent Decision because it is a co-equal body proceedings ○ They contend that the DARAB decision was Statement of Facts rendered without affording petitioners any notice ● Petra Piit previously owned a lot in Cagayan de Oro and hearing. (CDO). A portion of this lot was sold to Springfield which ● 25 June 1997 – on motion by the farmer-beneficiaries, the then developed the property into a subdivision called Mega RTC dismissed the case for lack of jurisdiction Heights Subdivision ● 2 July 1997 – Springfield and Piit filed with the CA a ● 4 May 1990 – DAR, through its Municipal Agrarian Reform special civil action for certiorari, mandamus, and Officer, issued a Notice of Coverage placing the property prohibition with prayer for the issuance of writ of under the coverage of RA 6657 or the Comprehensive preliminary injunction and/or TRO Agrarian Reform Law (CARL) of 1988 ○ Alleged that the RTC committed grave abuse of ○ Piit opposed said coverage discretion when it ruled that the annulment of ● 27 August 1991 – DARAB Provincial Adjudicator Salcedo judgment filed before it is actually an action for declared the property as residential and not suitable for certiorari in a different color agriculture ○ Stated that what it sought before the RTC is an ○ The Regional Director filed a notice of appeal which annulment of the DARAB Decision and not Salcedo disallowed for being pro forma and certiorari, as the DARAB Decision is void ab initio frivolous for having been rendered without due process of law. ● 16 July 1998 – CA dismissed the petition ruling that RTC In Ngo Bun Tiong v. Sayo, the Court expressed that pursuant to does not have jurisdiction to annul the DARAB Decision the policy of judicial stability, the doctrine of non-interference because it is a co-equal body between concurrent and coordinate courts should be regarded as ● 12 January 1999 – CA ordered the elevation of the DARAB highly important in the administration of justice whereby the records before it declaring that it overlooked the fact that judgment of a court of competent jurisdiction may not be opened, Springfield and Piit likewise applied for a writ of prohibition modified or vacated by any court of concurrent jurisdiction. against the enforcement of the DARAB decision which they claim to be patently void. With the introduction of BP 129, the rule on annulment of ● 23 February 2000 – CA dismissed the MR without judgments was specifically provided in Section 9(2) which vested specifically resolving the issue regarding the writ of in the then IAC the exclusive original jurisdiction over actions for prohibition annulment of judgments of RTCs. According to the Interim Rules and Guidelines implementing B.P. Blg. 129, the quasi-judicial Applicable Laws: bodies whose decisions are exclusively appealable to the CA are BP 129 or the Judiciary Reorganization Act of 1980. those, which under the law, R.A. No. 5434,24 or its enabling acts, are specifically appealable to the CA. Issues: Does the RTC have jurisdiction to annul a final judgment of the BP 129 does not specifically provide for any power of the RTC to DARAB? No. The RTC does not have the power to annul a annul judgments of quasi-judicial bodies. But in the case of BF decision rendered by a court or quasi-judicial body of equal Northwest Homeowners Association, Inc. v. IAC, the Court held ranking. that RTCs have jurisdictions over action for annulment of judgments of inferior courts and administrative or quasi-judicial Rationale bodies of equal ranking with such inferior courts. The petition for annulment of the DARAB decision was filed with the RTC on June 13, 1997, before the advent of the 1997 Rules of DARAB is a a quasi-judicial body created by Executive Order Nos. Civil Procedure, which took effect on July 1, 1997. Thus, the 229 and 129-A. R.A. No. 6657 delineated its adjudicatory powers applicable law is B.P. Blg. 129 or the Judiciary Reorganization Act and functions. The DARAB Revised Rules of Procedure adopted of 1980, enacted on August 10, 1981. on December 26, 1988 specifically provides for the manner of judicial review of its decisions, orders, rulings, or awards. Rule Before BP 129, a CFI has the authority to annul a final and XIV, Section 1 states: executory judgment rendered by another CFI or by another branch of the same court. But in later cases, the Court held that the better SECTION 1. Certiorari to the Court of Appeals. Any decision, policy, as a matter of comity or courteous interaction between order, award or ruling by the Board or its Adjudicators on any courts of first instance and the branches thereof, is for the agrarian dispute or on any matter pertaining to the application, annulment cases to be tried by the same court or branch which implementation, enforcement or interpretation of agrarian reform heard the main action. laws or rules and regulations promulgated thereunder, may be brought within fifteen (15) days from receipt of a copy thereof, to the Court of Appeals by certiorari, except as provided in the next succeeding section. Notwithstanding an appeal to the Court of Appeals the decision of the Board or Adjudicator appealed from, shall be immediately executory.
Further, the prevailing 1997 Rules of Civil Procedure, as
amended, expressly provides for an appeal from the DARAB decisions to the CA.
The rule is that where legislation provides for an appeal from
decisions of certain administrative bodies to the CA, it means that such bodies are co-equal with the RTC, in terms of rank and stature, and logically, beyond the control of the latter. Given that DARAB decisions are appealable to the CA, the inevitable conclusion is that the DARAB is a co-equal body with the RTC and its decisions are beyond the RTC's control. The CA was therefore correct in sustaining the RTC's dismissal of the petition for annulment of the DARAB Decision as the RTC does not have any jurisdiction to entertain the same.
Related issue: WON the petition for annulment of the DARAB
judgment could be brought to the CA. No. BP 129 vested CA the exclusive original jurisdiction over actions for annulment of judgments but only those rendered by the RTC. It does not expressly give the CA the power to annul judgments of quasi-judicial bodies. Also, previous decisions held that the silence of B.P. Blg. 129 on the jurisdiction of the CA to annul judgments or final orders and resolutions of quasi-judicial bodies like the DARAB indicates its lack of such authority.
Judgment: The petition is PARTLY GRANTED and is remanded
to the CA which is directed to resolve the prayer for the issuance of the writ of prohibition.
Notes: Wala na. Laverrn lag guythz, malapit na ang christmas