LAND BANK OF THE PHILIPPINES v. VILLEGAS GR No. 180384 whole province.
. 180384 whole province. As for the heirs of Noel, LBP had already paid them for their
March 26, 2010 Abad, J.
TOPIC IN SYLLABUS: Jurisdiction
SUMMARY: LBP filed cases for determination of just compensation against
Villegas and heirs of Noel before RTC Br. 32 of Dumaguete City, the
designated SAC of Negros Oriental. The subject lands were located in
Guihulngan City and Bayawan City, which are outside the regular territorial
jurisdiction of RTC Br. 32. 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 has jurisdiction over all cases of determination of
just compensation within the province of Negros Oriental, regardless of WoN
the properties are outside its regular jurisdiction.
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 involving 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
Corazon Villegas, and heirs of Catalino Noel and Procula Sy before the RTC of
Dumaguete City Br.32, sitting as a Special Agrarian Court (SAC) for the
province of Negros Oriental. Villegas’ property was in Guihulngan City, while
the heirs’ land was in Bayawan City, both in Negros Oriental, but which were
outside the regular territorial jurisdiction of RTC Br. 32 of Dumaguete City.
RTC Br. 32 dismissed both cases for lack of jurisdiction, ruling that, although it
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 jurisdiction of Guihulngan City and Bayawan City.
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 law.
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
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land.
ISSUE(S): WoN an RTC, acting as Special Agrarian Court, has jurisdiction over
just compensation cases involving agricultural lands located outside its
regular jurisdiction but within the province where it is designated as an
agrarian court under the Comprehensive Agrarian Reform Law of 1998 —Y
HELD:
Jurisdiction is the court’s authority to hear and determine a case. Such
jurisdiction over the nature and subject matter of an action is conferred by law.
In the case at bar, Secs. 56 and 57 of the CARL of 1998 provide that a branch
of an RTC designated as SAC for a province has original and exclusive
jurisdiction over all petitions for the determination of just compensation and
prosecution of all criminal offenses under CARL in that province (Republic v.
CA).
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
involving agricultural lands located outside their regular territorial jurisdiction,
so long as they are within the province where they sit as SACs.
CARL requires the designation of the SC before an RTC branch can function as
a SAC. Br. 64 of Guihulngan City and Br. 63 of Bayawan City have not been
designated as SAC by the SC. Consequently, they cannot hear just
compensation just because the lands subject of such cases happen to be within
their territorial jurisdiction. Since RTC Br. 32 of Dumaguete City is the
designated SAC for Negros Oriental, it has jurisdiction over all cases of
determination of just compensation involving agricultural lands within that
province, regardless of WoN those properties are outside its regular territorial
jurisdiction.
SC GRANTS the petitions and SETS ASIDE the orders of RTC Br. 32 of
Dumaguete City. The Court DIRECTS said RTC to immediately hear and decide
the 2 cases unless a compromise agreement has been approved.
NOTE: The scra states that it’s a Special Civil Action for certiorari (R65), but
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).
Case # 13