TL;DR
The Supreme Court affirmed that the Department of Agrarian Reform Adjudication Board (DARAB), a quasi-judicial body, does not have the power to issue writs of certiorari. This means DARAB cannot review and overturn decisions of its own Regional Agrarian Reform Adjudicators (RARADs) through certiorari petitions. Individuals seeking to challenge RARAD decisions must file a petition for certiorari with the proper Regional Trial Court, not directly with DARAB. This ruling reinforces the separation of powers, ensuring that only courts with judicial power can issue certiorari, and protects the integrity of agrarian dispute resolution processes by directing appeals to the correct judicial bodies.
Beyond Board Authority: Why DARAB Can’t Issue Writs of Certiorari
Imagine seeking justice for an agrarian dispute, only to find the very board meant to help you is powerless in a crucial way. This case, Land Bank of the Philippines v. Magdalena Quilit and Mauricio Laoyan, revolves around whether the Department of Agrarian Reform Adjudication Board (DARAB) can issue writs of certiorari – a legal tool to correct grave abuse of discretion by lower tribunals. Land Bank of the Philippines (LBP) filed a petition for certiorari with DARAB to challenge a RARAD decision it deemed unlawful. This action was based on the DARAB’s own rules of procedure at the time, which seemingly allowed such petitions. However, the Supreme Court stepped in to clarify a fundamental principle: DARAB, as a quasi-judicial body, lacks the inherent judicial power to issue certiorari.
The factual backdrop involves a land dispute originating from a petition filed by Magdalena Quilit and Mauricio Laoyan against LBP. The RARAD ruled in favor of Quilit and Laoyan, allowing them to redeem foreclosed agricultural lands. LBP, feeling aggrieved, attempted to appeal, but its appeal was deemed late. Subsequently, LBP filed a Petition for Certiorari with DARAB, seeking to annul the RARAD’s decision. DARAB dismissed LBP’s petition for lack of jurisdiction, citing the Supreme Court’s ruling in Department of Agrarian Reform Adjudication Board v. Lubrica, which explicitly stated DARAB’s lack of authority to issue certiorari writs. The Court of Appeals (CA) upheld DARAB’s dismissal, leading LBP to elevate the matter to the Supreme Court.
The central legal question before the Supreme Court was whether DARAB, a quasi-judicial body, could entertain petitions for certiorari. LBP argued that the DARAB rules in force at the time allowed such petitions and that applying the Lubrica ruling retroactively would unfairly prejudice them. However, the Supreme Court firmly rejected LBP’s arguments, citing both Lubrica and the more recent case of Heirs of Zoleta v. Land Bank of the Philippines. These cases established a clear doctrine: DARAB’s jurisdiction is limited to what is expressly granted by law, and neither Republic Act No. 6657 (Comprehensive Agrarian Reform Law) nor its implementing executive orders confer certiorari powers upon DARAB.
The Court emphasized that the power to issue certiorari is inherently judicial, belonging to courts of law, not administrative agencies like DARAB. To allow DARAB to issue certiorari writs would violate the fundamental principle of separation of powers. As the Supreme Court in Zoleta eloquently stated:
As an administrative agency exercising quasi-judicial but not consummate judicial power, DARAB is inherently incapable of issuing writs of certiorari. This is not merely a matter of statutorily stipulated competence but a question that hearkens to the separation of government’s tripartite powers: executive, legislative, and judicial.
The Supreme Court clarified that while DARAB can create its own rules of procedure, these rules cannot expand its jurisdiction beyond what is legally granted. The rule in the 1994 DARAB New Rules of Procedure that seemingly allowed certiorari petitions was deemed an invalid attempt to confer judicial power upon a quasi-judicial body. The Court also dismissed LBP’s plea for prospective application of the Lubrica ruling, stating that the lack of jurisdiction is a fundamental defect that cannot be cured by procedural rules or equitable considerations.
Furthermore, the Court noted that even under the 1994 DARAB rules, LBP failed to comply with the requirement of filing a motion for reconsideration with the RARAD within five days before filing a certiorari petition with DARAB. This procedural lapse further weakened LBP’s position. Ultimately, the Supreme Court affirmed the CA’s decision, denying LBP’s petition and reinforcing the principle that DARAB lacks certiorari jurisdiction. This ruling ensures that challenges to RARAD decisions must be pursued through the correct legal channels, specifically via certiorari petitions filed with the Regional Trial Court, maintaining the proper allocation of judicial power and upholding the rule of law in agrarian dispute resolution.
FAQs
| What is a writ of certiorari? | A writ of certiorari is a court order used to review and correct errors of jurisdiction or grave abuse of discretion committed by a lower court or quasi-judicial body. |
| Is DARAB a court? | No, DARAB is a quasi-judicial body, an administrative agency with adjudicatory powers delegated by the Department of Agrarian Reform (DAR). It is part of the Executive branch, not the Judicial branch of government. |
| Why can’t DARAB issue certiorari? | DARAB lacks the inherent judicial power to issue writs of certiorari. This power is reserved for courts of law as part of the judicial power vested in them by the Constitution. Granting this power to DARAB would violate the separation of powers. |
| What should Land Bank have done instead of filing certiorari with DARAB? | Land Bank should have filed a petition for certiorari with the Regional Trial Court (RTC) to challenge the RARAD’s decision. This is the proper court with jurisdiction to issue certiorari against quasi-judicial bodies like RARAD. |
| What is the practical implication of this ruling? | Parties in agrarian disputes must be aware that DARAB cannot review RARAD decisions through certiorari. They must seek judicial review from the proper courts, like the RTC, if they believe a RARAD decision was issued with grave abuse of discretion or lack of jurisdiction. |
| Does this ruling invalidate DARAB’s rules of procedure? | Yes, to the extent that DARAB rules purported to grant itself certiorari jurisdiction, those rules are invalid. Administrative agencies cannot expand their jurisdiction through their own rules beyond what is authorized by law. |
For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.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: LAND BANK OF THE PHILIPPINES VS. MAGDALENA QUILIT AND MAURICIO LAOYAN, G.R. No. 194167, February 10, 2021
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