Hon. Carlos O. Fortich vs. Hon. Renato C.

Corona
G.R. No. 131457 April 24, 1998
Martinez, J.:

Facts:
A 144 hectare land located in San Vicente, Sumilao, Bukidnon owned by Noberto Quisubing , Sr.
Management and Development Corporation(NQSRMDC), was entered through a lease of
agreement to Del Monte Philippines Inc. for ten years. During the existence of the lease the 144
hectare land was placed by DAR under compulsory acquisition pursuant to CARL and assessed
the land value.
NQSRMDC, resisted the DARs action, which was granted by the DARAB, through the PARAD.
Nevertheless despite the order of DARAB, the DAR regional Director issued a memorandum
ordering the Land Bank of the Philippines to open a trust account in the name of NQSRMDC and
conduct summary proceeding to determine the just compensation, which was objected by
NQSRMDC and file an omnibus motion to enforce the order of DARAB which was granted.
In the meantime, the Provincial Development Council headed by Governor Fortich passed
Resolution No. 6, designating certain areas along Bukidnon-Sayre Highway as part of the
Bukidnon Agro-Industrial Zones where the subject property is situated. Thereafter, the
Sanguniang Bayan of Sumilao Bukidnon passed an ordinance reclassifying the 144 hectares
subject property from agricultural to agro-industrial land, to attract investors who can inject
new economic vitality, provide more jobs and raise the income of its people.
However, DAR secretary Garilao invoking its power to approve conversion of the land,
disapprove the conversion and and it placed the land to compulsory acquisition program.
Governor Fortich then filed an appeal of the Decision of the DAR to the office of the President
which was granted.
Thereafter, some alleged farmer beneficiaries began their hunger strikes in front of DAR
compound to protest against the conversion of the 144 subject property. President Fidel V.
Ramos held a dialogue with the strikers and created fact finding task force, that recommend a
win/win resolution penned by then deputy secretary Renato C. Corona, wherein only 44
hectares will be converted to agro-industrial land and the rest 100 hectare land to be given to
farmer beneficiaries.
The party of Governor Fortich then filed for the nullification if the win/win resolution and claim
that the Office of the President was prompted to issue the said resolution after a very well-
managed hunger strike led by fake farmer-beneficiary Linda Ligmon succeeded in pressuring
and/or politically blackmailing the Office of the President to come up with this purely political
decision to appease the farmers, by reviving and modifying the Decision of 29 March
1996 which has been declared final and executory in an Order of 23 June 1997.

Issue:
Whether or not the decision of the office of the president approving the conversion of the
agricultural land into agro industrial land can be modified by the win/win resolution

Held:
The court held that the win/win resolution is void and that the resolution made by the Office of
the President before issuing the win/win resolution has become final and executory. Pursuant to Sec. 7
of Administrative order no. 18, resolution of the office of the President shall become final and executory
after 15 days from the receipt thereof. Since there was no motion for reconsideration made on the
resolution such becomes final and executory, thus, a motion for reconsideration beyond the lapse of
fifteen days, the Office has lost its jurisdiction to reopen the case and modify it. Hence, the act of the
Office of the President in re-opening the case and substantially modifying its March 29,1996 Decision
which had already become final and executory, was in gross disregard of the rules and basic legal
precept that accord finality to administrative determinations.
The orderly administration of justice requires that the judgments/resolutions of a court or quasi-
judicial body must reach a point of finality set by the law, rules and regulations. The noble purpose is to
write finis to disputes once and for all



Rufina Vda De Tangub vs. Court of Appeals
191 scra 885
Narvasa, J.:

Facts:
Rufina Tangub together with her husband who is now deceased filed with Regional Court of
Lanao an Agrarian Case for damages by reason of the unlawful disposition who were tenants in
from a landholding owned by the spouses Domingo and Eugenia Martil. PNB was also impleaded
by foreclosing the land which was mortgaged to them by the spouses Martil. Petitioner then
also asked for the nullification of the mortgaged and foreclosure of the land.
The Regional Trial Court presided by Judge Felipe G. Javier, Jr. dismissed the complaint. He
opined that by virtue of Executive Order No. 229 "providing the mechanisms for the
implementation of the Comprehensive Agrarian Reform Program approved on July 24, 1987"
Executive No. 129-A approved on July 26, 1987, as well as the Rules of the Adjudication Board of
the Department of Agrarian Reform, jurisdiction of the Regional Trial Court over agrarian cases
had been transferred to the Department of Agrarian Reform.
Petitioner then appeal it to the Court of Appeals dismissed the petition, finding that the
jurisdictional question had been correctly resolved by the Trial Court. It emphatically ruled that
agrarian cases no longer fall under the jurisdiction of Regional Trial Courts but rather under the
jurisdiction of the DAR Adjudication Board.
The petitioner then contends that the decision of the Trial court and CA are illegal and
unconstitutional because they deprive a poor tenant access to courts.

Issue:
Whether or not the decision of RTC and CA violate the constitutional right of the petitioner
access to courts

Held:
The court held that The Regional Trial Court of Iligan City and the CA was correct in dismissing
the case it being a case concerning the rights of the plaintiffs as tenants on agricultural land, not
involving the "special jurisdiction" of said Trial Court acting as a Special Agrarian Court, it clearly came
within the exclusive original jurisdiction of the Department of Agrarian Reform, or more particularly, the
Agrarian Reform Adjudication Board, established precisely to wield the adjudicatory powers of the
Department pursuant to Section 56 of RA 6657.



Philippines Veterans Bank vs. CA
G.R. No. 132767 January 18, 2000
Mendoza, J.:

Facts:
The Philippine Veterans Bank who owned four parcels of land in Tagum, Davao was taken by
DAR for the redistribution to the farmer beneficiaries Pursuant to CARL. Dissatisfied with the
land valuation made by DAR, the Philippine Veterans Bank together with DARAN filed before the
Regional Trial Court of Tagum for the determination of Just compensation.
The Trial Court dismissed the petition foe it was filed beyond the 15-day reglementary period as
provided under Sec. 51 of RA 66to 57. On appeal to the Court of Appeals the decision of the trial
Court was affirmed and held that jurisdiction over land valuation cases is lodged in the
Department of Agrarian Reform Adjudication Board, as is plainly provided under Rule II of the
DARAB Revised Rules of Procedure.

Issue:
Whether or not the petition for the judicial fixing of just compensation before a special agrarian
court be filed be filed within the 15-day reglementary period and before the decision of the DAR
provincial adjudicator becomes final and executory

Held:
The court held that the petition in the Regional Trial Court was filed beyond the 15-day period
provided in Rule XIII, 11 of the Rules of Procedure of the DARAB, the trial court correctly dismissed the
case and the Court of Appeals correctly affirmed the order of dismissal. The jurisdiction of the Regional
Trial Courts is not any less "original and exclusive" because the question is first passed upon by the DAR,
as the judicial proceedings are not a continuation of the administrative determination. For that matter,
the law may provide that the decision of the DAR is final and unappealable. Nevertheless, resort to the
courts cannot be foreclosed on the theory that courts are the guarantors of the legality of administrative
action.


DAR vs. Robert Cuenca
G.R. No. 154112 September 23, 2004
Panganiban, J.:

Facts:
Roberto J. Cuenca is a registered owner of a parcel land containing an area of 81.6117 hectares,
situated in Barangay Haguimit, La Carlota City devoted in planting of sugarcane, in which his
land was covered by a notice of coverage putting the subject property into compulsory coverage
pursuant to CARL by the MARO.
Cuenca then filed into RTC a complaint against MARO and prayed for the annulment of the
notice coverage made by MARO into his land on ground that the implementation of CARP in his
landholding is no longer with authority of law considering that, if at all, the implementation
should have commenced and should have been completed between June 1988 to June 1992, as
provided in the Comprehensive Agrarian Reform Law (CARL); that the placing of the subject
landholding under CARP is without the imprimatur of the Presidential Agrarian Reform Council
(PARC) and the Provincial Agrarian Reform Coordinating Committee (PARCOM).
Noe Fortunado of MARO on one hand filed a motion to dismiss the complaint for the RTC has no
jurisdiction over the nature and subject of the case pursuant to RA 6657. Thereafter, the
respondent Judge issued a Temporary Restraining Order directing MARO to cease and desist
from implementing the Notice of Coverage. In the same order, the respondent Judge set the
hearing on the application for the issuance of a writ of preliminary injunction. A motion for
reconsideration was filed by MARO, but was dismissed by the trial court.
DAR then filed before the CA a petition for certiorari under Rule 65 of the 1997 Rules of Civil
Procedure, assailing the writ of preliminary injunction issued by respondent Judge on the
ground of grave abuse of discretion amounting to lack of jurisdiction. Petitioner contends that
by virtue of the above provisions, all lower courts, such as the court presided over by
respondent Judge, are barred if not prohibited by law to issue orders of injunctions against the
Department of Agrarian Reform in the full implementation of the Notice of Coverage which is
the initial step of acquiring lands under R.A. 6657. Furthermore, the nature and subject matter
of the case below is purely agrarian in character over which the trial court has no jurisdiction
and that therefore, it had no authority to issue the assailed injunction order. However, CA
dismisses the case.

Issue:
W/n the nature and subject matter of the case is purely agrarian in character and therefore the
RTC has no jurisdiction over the case.

Held:
The court held that pursuant to RA 6657 Sec. 50, the Quasi-Judicial Powers of the DAR is hereby
vested with primary jurisdiction to determine and adjudicate agrarian reform matters and shall have
exclusive original jurisdiction over all matters involving the implementation of agrarian reform, except
those falling under the exclusive jurisdiction of the Department of Agriculture and the Department of
Environment and Natural Resources. Thus, the case being purely agrarian in character, the jurisdiction
over the case is vested to DAR and that the RTC has no jurisdiction over the case.