The Supreme Court ruled that the Department of Agrarian Reform Adjudication Board (DARAB) does not have the authority to issue writs of certiorari. This decision clarifies that DARAB, as a quasi-judicial body, possesses only the powers expressly granted to it by law, ensuring that it operates within its defined scope in resolving agrarian disputes. This ruling underscores the importance of adhering to jurisdictional boundaries in administrative proceedings.

Agrarian Justice: When Can DARAB Overturn its Own Adjudicators?

The case revolves around a dispute over the just compensation for landholdings in Sablayan, Occidental Mindoro, owned by Federico Suntay. The Department of Agrarian Reform (DAR) and the Land Bank of the Philippines (Land Bank) valued the land at P4,251,141.68, but Suntay argued that this valuation was unconscionably low. The Regional Agrarian Reform Adjudicator (RARAD) initially ruled in favor of Suntay, ordering Land Bank to pay P157,541,951.30 as just compensation. Land Bank filed a petition for just compensation with the Regional Trial Court (RTC), but it was dismissed for failure to pay docket fees. Subsequently, Land Bank filed a petition for certiorari with the DARAB, seeking to nullify the RARAD’s decision. Josefina Lubrica, as assignee of Suntay’s rights, then filed a petition for prohibition with the Court of Appeals to enjoin DARAB from proceeding with the case, arguing that DARAB lacked jurisdiction over special civil actions for certiorari.

The Court of Appeals sided with Lubrica, holding that DARAB’s exercise of jurisdiction over the petition for certiorari had no constitutional or statutory basis. The appellate court declared that DARAB was without jurisdiction to take cognizance of the case. The central question before the Supreme Court was whether DARAB, as a quasi-judicial body, had the authority to issue writs of certiorari, which is a power to review and potentially overturn decisions of lower adjudicators, namely the RARAD.

The Supreme Court emphasized that jurisdiction must exist as a matter of law, either expressly conferred by the Constitution or by statute. Issuing writs of certiorari involves the exercise of original jurisdiction, which cannot be implied. The court reviewed the relevant laws, including Executive Order (E.O.) No. 229, E.O. No. 129-A, and Republic Act (R.A.) No. 6657, which created the DARAB and defined its powers. While these laws granted DARAB adjudicatory functions and the power to resolve agrarian disputes, they did not explicitly confer the authority to issue writs of certiorari. The Supreme Court held that in the absence of a specific statutory grant of jurisdiction to issue certiorari, DARAB could not exercise such authority. Neither the quasi-judicial authority of the DARAB nor its rule-making power could justify the self-conferment of such authority.

“In general, the quantum of judicial or quasi-judicial powers which an administrative agency may exercise is defined in the enabling act of such agency. In other words, the extent to which an administrative entity may exercise such powers depends largely, if not wholly, on the provisions of the statute creating or empowering such agency.”

The Court noted that the DARAB’s jurisdiction is limited and special, confined to hearing and determining cases within its competence and expertise. It acknowledged DARAB’s supervisory authority over the RARADs and PARADs but clarified that this supervision should be exercised within the context of administrative supervision and control, not through the issuance of writs of certiorari. In addition, Rule XIII, §11 of the DARAB Rules of Procedure allows a party who does not agree with the RARAD’s preliminary valuation in land compensation cases fifteen (15) days from receipt of notice to bring the matter to the proper special agrarian court. DARAB sought to justify its actions by arguing that it was merely exercising its power of supervision to ensure that the RARAD acted within its delegated authority.

The Supreme Court firmly rejected this argument, stating that the power to correct errors of jurisdiction is typically lodged with regular courts, not with administrative agencies absent an express constitutional or legislative grant. The Court emphasized that while the DARAB could adopt its own rules of procedure, this did not give it the discretion to grant itself jurisdiction that is ordinarily conferred only by the Constitution or by law.

FAQs

What was the key issue in this case?	The main issue was whether the Department of Agrarian Reform Adjudication Board (DARAB) has the jurisdiction to issue writs of certiorari. This power would allow it to review and potentially overturn decisions of lower agrarian adjudicators.
What did the Supreme Court decide?	The Supreme Court held that DARAB does not have the authority to issue writs of certiorari. This is because no law expressly grants it that power.
Why does DARAB claim it has this power?	DARAB argued that issuing the writ was part of its supervisory power over lower adjudicators. It was trying to ensure they acted within their delegated authority and did not abuse their jurisdiction.
What is a writ of certiorari?	A writ of certiorari is a court order that reviews a lower court’s decision for errors. It allows a higher court to correct jurisdictional mistakes.
What is a quasi-judicial body?	A quasi-judicial body like DARAB has powers similar to a court. However, its powers are limited to specific areas. In DARAB’s case, this area is agrarian reform.
What does this ruling mean for landowners?	This ruling means landowners cannot seek certiorari from DARAB. To challenge RARAD decisions, landowners must turn to the Special Agrarian Courts or other bodies.
What is the role of the Regional Agrarian Reform Adjudicator (RARAD)?	The RARAD hears and decides agrarian cases within a specific region. Its decisions can be appealed but not through a petition for certiorari with DARAB.
Did DARAB overstep its authority in this case?	Yes, the Supreme Court decided that DARAB overstepped its authority. DARAB does not have the power to issue a writ of certiorari despite it being an adjunct of, but not totally independent from, DAR.

In conclusion, the Supreme Court’s decision affirms that the DARAB’s powers are limited to those expressly granted by law, ensuring that the agency operates within its defined scope. The determination that the DARAB cannot issue writs of certiorari solidifies the principle that quasi-judicial bodies must adhere to jurisdictional boundaries and reinforces the judicial system’s structure for handling legal challenges in agrarian disputes. This outcome clarifies the remedies available to parties involved in agrarian disputes, directing them to the appropriate venues for judicial review and recourse.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD (DARAB) OF THE DEPARTMENT OF AGRARIAN REFORM (DAR) VS. JOSEFINA S. LUBRICA, G.R. NO. 159145, April 29, 2005