SPRINGFIELD

DEVELOPMENT CORPORATION, INC. and HEIRS OF PETRA CAPISTRANO

PIIT

v.

HONORABLE PRESIDING JUDGE OF REGIONAL TRIAL COURT OF MISAMIS ORIENTAL,

BRANCH 40, CAGAYAN DE ORO CITY, DEPARTMENT OF AGRARIAN REFORM
ADJUDICATION BOARD (DARAB), DAR REGION X DIRECTOR, ROSALIO GAMULO,
FORTUNATO TELEN, EMERITA OLANGO, THERESA MONTUERTO, DOMINGO H.
CLAPERO, JOEL U. LIM, JENEMAIR U. POLLEY, FIDELA U. POLLEY, JESUS BATUTAY,
NICANOR UCAB, EMERIA U. LIM, EMILITO CLAPERO, ANTONINA RIAS, AURILLIO
ROMULO, ERWIN P. CLAPERO, EVELITO CULANGO, VILMA/CRUISINE ALONG, EFREN
EMATA, GREGORIO CABARIBAN, and SABINA CANTORANA,

Date: Feb 6 2007

Ponente: J. Austria-Martinez

Facts:

Rule 45 Certiorari

• Petra Capistrano Piit owned Lot 2201 in Cagayan de oro (123,408 sqm)
• Springfield bough lot 2291-C (68,732 sqm) and 2291-D (49778 sqm) and
developed to Mega Heights Subdivision (name ng subdi)
• May 4, 1990 – Dep of Ag Reform (DAR) issued a notice of coverage placing the
property under CARP (RA6657)
• Heirs of Petre opposed and case was docketed at Dept of Ag Reform Adjudication
Board (DARAB)
• DARAB Provincial Adjudicator ruled that it is residential and not agricultural
• Regional Director filed notice of appeal but Provincial Adjudicator disallowed for
being proforma and frivolous
• Decision became final and executor
• Regional Director filed a petition for relief of judgement before DARAB
• DARAB granted and ordered to proceed with documentation and distribution of
property to the beneficiaries
• However, since the subdivision has already been constructed, DARAB ordered
Springfield and heirs of Petra to pay 12,340,800 pesos to the beneficiaries
• Heirs of Petra filed before RTC of CDO for annulment of the DARAB decision and
all subsequent proceedings for lack of notice and hearing
• RTC Dismissed the case for lack of jurisdiction
• Heirs of Petra and Springfield filed before the CA Special Civil action for
certiorari, mandamus, and prohibition with prayer for the issuance of writ of
preliminary injunction and/or temporary restraining order
o Petra arguments:
§ what they sought was annulment of decision and not certiorari
§ void ab initio for rendering decision without due process of law
• CA dismissed the position because RTC is co-equal with DARAB = lack of
jurisdiction

• However, a few months after, CA ordered the elevation of DARAB records as it

may have overlooked on the writ of prohibition sought by Petra et al.
• PERO WALA DENIED DIN
• MR before CA but denied pa rin

ISSUE: WON RTC has jurisdiction to annul a final judgement of the DARAB (NO but yes
on appeal of decisions)

Held

• This case was filed before the advent of the 1997 Rules on CIVPRO which too
effect on July 1 1997. Thus, BP 129 is the applicable law
• Before BP 129, CFI had authority to annul decisions of another CFI. This was
removed for better policy and comity. (Doctrine of non-interferance on
concurrent and coordinate courts)
• Because of BP 129, CA has original jurisdiction over actions on annulment of
judgements of RTC, also vested the CA with “exclusive appellate jurisdiction over
all final judgments, decisions, resolutions, orders, or awards of Regional Trial
Courts and quasi-judicial agencies, instrumentalities, boards or commissions,
except those falling within the appellate jurisdiction of the Supreme Court in
accordance with the Constitution, the provisions of this Act, and of sub-
paragraph (1) of the third paragraph and subparagraph (4) of the fourth
paragraph of Section 17 of the Judiciary Act of 1948.”
• BP 129 does not specifically provide for any power of the RTC to annul
judgements of quasi-judicial bodies
• In BF Northwest Homeowners v IAC, the Court ruled RTCs have jurisdiction over
the National Water Resources Council which is a quasi-judicial body ranked with
inferior courts
• However, DARAB is not an inferior Court
o EO229 creating DARAB and its Revised Rules specifically provides the
manner of judicial review
§ “SECTION 1. Certiorari to the Court of Appeals.—Any decision,
order, award or ruling by the Board or its Adjudicators on any
agrarian dispute or on any matter pertaining to the application,
implementation, enforcement or interpretation of agrarian reform
laws or rules and regulations promulgated thereunder, may be
brought within fifteen (15) days from receipt of a copy thereof, to
the Court of Appeals by certiorari, except as provided in the next
succeeding section. Notwithstanding an appeal to the Court of
Appeals the decision of the Board or Adjudicator appealed from,
shall be immediately executory.
o 1997 CIVPRO PROVIDES DIRECT APPEAL TO CA
o Given that DARAB decisions are appealable to the CA, the inevitable
conclusion is that the DARAB is a co-equal body with the RTC and its
decisions are beyond the RTC’s control. The CA was therefore correct
in sustaining the RTC’s dismissal of the petition for annulment of the
DARAB Decision dated October 5, 1995, as the RTC does not have any
jurisdiction to entertain the same.
• Issue WON CA can annul DARAB judgement (No)

o BP129 only gives exclusive original jurisdiction over annulment of

judgements rendered by RTCs not expressly on quasi judicial bodies
o Elcee farms v Semillano
§ CA cannot annul NLRC decision
o Galang v CA
§ CA cannot annul SEC decision
o Cole v CA
§ Cannot annul HLURB decision
• Petitioners now want SC to act on the writ of prohibition as CA did not do it
o Fortrich v CA
§ SC took cognizance of the writ and decided on the case due to
compelling reasons, as there was a decision by the Office of the
President with respect to the land supposed to be given to the
farmer beneficiaries who conducted a strike.
§ This is not applicable to this case
§ It must be stressed at this point that the Court, as a rule, will not
entertain direct resort to it unless the redress desired cannot be
obtained in the appropriate courts, and exceptional and
compelling circumstances, such as cases of national interest and of
serious implications, justify the availment of the extraordinary
remedy of writ of certiorari, prohibition, or mandamus calling for
the exercise of its primary jurisdiction
• At first SC considered resolving the merits on the writ of prohibition but CA
failed to submit to SC. SC then decided it is best to remand the case as CA is more
empowered to determine the probative value of evidence by its rules.
• REMANDED to CA