Vivencio, Eugenio, Joji and Myrna, All Surnamed Mateo vs. Department of Agrarian Reform, Land Bank of the Philippines and Mariano T. Rodriguez, et al. G.R. No. 186339, February 15, 2017, REYES, J.
While the Court recognizes the primacy of the doctrine of exhaustion of administrative remedies in our
judicial system, it bears emphasizing that the principle admits of exceptions, among which is when
there is unreasonable delay or official inaction that irretrievably prejudices a complainant.
FACTS:
The Mateos were the registered owners of [coconut and rice lands] with a total area of 1,323,112 square meters situated at Fabrica, Bacon, Sorsogon and [were] covered by TCT No. T-22822. A portion of the land[s] was brought under the coverage of the CARP of the government and for this reason, the DAR entered the premises sometime in June 1994. LBP valued the Mateos' land at fiftytwo thousand pesos (₱52,000.00) per [ha]. The Mateos, however, rejected the LBP's valuation. On April 30, 1997, the Mateos filed a complaint against LBP, DAR, and the farmer beneficiaries of the land for just compensation. The case was docketed as Civil Case No. 97-6331 and raffled to the RTC of Sorsogon City, Branch 52, sitting as a Special Agrarian Court (SAC), presided by respondent Judge Honesto A. Villamor. The LBP and DAR filed their respective answers arguing that since no summary administrative proceedings to determine the amount of just compensation had been conducted yet, the complaint of the Mateos was premature. The SAC fixed the amount of just compensation to P71, 143, 623.00 and ordered LBP to pay the Mateos the said amount. The CA rendered a decision setting aside the SAC's judgment and dismissing without prejudice the complaint of the Mateos.
ISSUE:
Whether or not the CA erred in negating the jurisdiction of the RTC, as a SAC, to determine in the first instance and in the absence of the conduct of prior administrative proceedings, questions of just compensation to be paid to landowners.
RULING:
Yes, While the Court recognizes the primacy of the doctrine of exhaustion of administrative remedies in our judicial system, it bears emphasizing that the principle admits of exceptions, among which is when there is unreasonable delay or official inaction that irretrievably prejudices a complainant. This exception is attendant herein where the LBP and the DAR entered the property of the Mateos sometime in 1994, but deposited cash and Agrarian Reform Bonds as payment therefor only on December 13, 1996 and February 11, 1997. The LBP and the DAR were indisputably aware that the Mateos rejected the price offered as just compensation for the subject property. Still, at the time the Mateos filed their suit before the SAC, no summary administrative proceeding was yet initiated by the DAR to make further valuation. The SAC even had to issue no less than three orders dated November 12, 1997, January 7, 1998 and March 18, 1998 for the DAR to conduct the necessary proceedings. DAR's delay and inaction had unjustly prejudiced the Mateos and precluding them from filing a complaint before the SAC shall result in an injustice, which the law never intends.
Source:
DEAN’S CIRCLE 2019 – UST FACULTY OF CIVIL LAW, retrieved April 24, 2020, from https://irp-cdn.multiscreensite.com/7dcde495/files/uploaded/Civil%20Procedure_MwNwIo5Rs6cBBO1gwlro.pdf
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