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LAND BANK OF THE PHILIPPINES v. GR No.

180384 ISSUE(S): WoN an RTC, acting as Special Agrarian Court, has jurisdiction
VILLEGAS over just compensation cases involving agricultural lands located outside its
March 26, 2010 Abad, J. regular jurisdiction but within the province where it is designated as an
TOPIC IN SYLLABUS: Jurisdiction agrarian court under the Comprehensive Agrarian Reform Law of 1998 —Y
SUMMARY: LBP filed cases for determination of just compensation against
Villegas and heirs of Noel before RTC Br. 32 of Dumaguete City, the designated HELD:
SAC of Negros Oriental. The subject lands were located in Guihulngan City and Jurisdiction is the court’s authority to hear and determine a case. Such jurisdiction
Bayawan City, which are outside the regular territorial jurisdiction of RTC Br. 32. over the nature and subject matter of an action is conferred by law.
As such, RTC, Br. 32 dismissed both cases. LBP’s MRs were also dismissed,
prompting it to file petitions for certiorari before the SC. SC ruled that RTC Br. 32 In the case at bar, Secs. 56 and 57 of the CARL of 1998 provide that a branch of an
has jurisdiction over all cases of determination of just compensation within the RTC designated as SAC for a province has original and exclusive jurisdiction over
province of Negros Oriental, regardless of WoN the properties are outside its all petitions for the determination of just compensation and prosecution of all
regular jurisdiction. criminal offenses under CARL in that province (Republic v. CA).
DOCTRINE: By “special” jurisdiction, SACs exercise power in addition to or over
and above the ordinary jurisdiction of the RTC, such as taking cognizance of suits By “special” jurisdiction, SACs exercise power in addition to or over and above the
involving agricultural lands located outside their regular territorial jurisdiction, so ordinary jurisdiction of the RTC, such as taking cognizance of suits involving
long as they are within the province where they sit as SACs. agricultural lands located outside their regular territorial jurisdiction, so long as
they are within the province where they sit as SACs.
FACTS:
Land Bank (LBP) filed cases for determination of just compensation against CARL requires the designation of the SC before an RTC branch can function as a
Corazon Villegas, and heirs of Catalino Noel and Procula Sy before the RTC of SAC. Br. 64 of Guihulngan City and Br. 63 of Bayawan City have not been
Dumaguete City Br.32, sitting as a Special Agrarian Court (SAC) for the province designated as SAC by the SC. Consequently, they cannot hear just compensation
of Negros Oriental. Villegas’ property was in Guihulngan City, while the heirs’ land just because the lands subject of such cases happen to be within their territorial
was in Bayawan City, both in Negros Oriental, but which were outside the regular jurisdiction. Since RTC Br. 32 of Dumaguete City is the designated SAC for Negros
territorial jurisdiction of RTC Br. 32 of Dumaguete City. Oriental, it has jurisdiction over all cases of determination of just compensation
involving agricultural lands within that province, regardless of WoN those
RTC Br. 32 dismissed both cases for lack of jurisdiction, ruling that, although it properties are outside its regular territorial jurisdiction.
was designated as the SAC for Negros Oriental, such designation did not expand its
territorial jurisdiction to hear agrarian cases, which are within the territorial SC GRANTS the petitions and SETS ASIDE the orders of RTC Br. 32 of
jurisdiction of Guihulngan City and Bayawan City. Dumaguete City. The Court DIRECTS said RTC to immediately hear and decide
the 2 cases unless a compromise agreement has been approved.
LBP moved for reconsideration of the 2 cases but Br. 32 dismissed the motions.
LBP directly filed petitions for certiorari before the SC, raising purely a question of NOTE: The scra states that it’s a Special Civil Action for certiorari (R65), but
law. it was mentioned in the body that the petition for certiorari was directly filed
with the SC since it raised only questions of law (R45).
RESPONDENT’S ARGUMENT(S): RTC, Br. 32 based its order on Deputy
Court Administrator Zenaida Elepaño’s opinion that single sala courts have
jurisdiction over agrarian cases involving lands located within its territorial
jurisdiction. Furthermore, the RTC’s designation as a SAC did not expand its
territorial jurisdiction. The jurisdiction of such SAC over agrarian cases is co-
extensive with its territorial jurisdiction. While it has been designated as SAC for
the Province of Negros Oriental, its jurisdiction as an RTC did not cover the whole
province. As for the heirs of Noel, LBP had already paid them for their land.

Maite Fernandez Page 1 of 1 Case # 13

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