Land Bank of the Philippines vs.

Celada
G.R. No. 164876
January 23, 2006

FACTS:
Respondent Leonila P. Celada, owns agricultural in Calatrava, Carmen, Bohol identified in 1998 by the
DAR as suitable for compulsory acquisition under the CARP. LBP valued respondent's land at
P2.1105517 per square meter for an aggregate value of P299,569.61. The DAR offered the same
amount, but it was rejected.
LBP filed its Answer raising non-exhaustion of administrative remedies as well as forum-
shopping as affirmative defense. According to petitioner, respondent must first await the outcome of
the DARAB case before taking any judicial recourse; that its valuation was arrived at by applying the
formula prescribed by law whereas respondents was based only on the “current value of like
properties”. the SAC fixes the compensation of the land of petitioner at P354,847.50 and which shall
earn legal interest of twelve percent (12%) per annum from the time of its taking by the DAR and to
indemnify petitioner for attorney’s fee and incidental expenses. LBP elevated the matter to the Court
of Appeals which, however, dismissed the appeal outright. Upon denial of its motion for
reconsideration, LBP filed the instant petition under Rule 45 of the Rules of Court, hence this
petition.

ISSUE:
Whether or not the SAC a quo erred in assuming jurisdiction over the petition for determination of
just compensation while administrative proceedings is on-going before the DARAB, Region VII, Cebu
City.

RULING:
No. In Land Bank of the Philippines v. Court of Appeals, the landowner filed an action for
determination of just compensation without waiting for the completion of the DARAB’s re-evaluation
of the land. The Court nonetheless held therein that the SAC acquired jurisdiction over the action for
the following reason: It is clear from Sec. 57 that the RTC, sitting as a Special Agrarian Court, has
‘original and exclusive jurisdiction over all petitions for the determination of just compensation to
landowners.’ This ‘original and exclusive’ jurisdiction of the RTC would be undermined if the DAR
would vest in administrative officials’ original jurisdiction in compensation cases and make the RTC
an appellate court for the review of administrative decision.
Thus, although the new rules speak of directly appealing the decision of adjudicators to the
RTCs sitting as Special Agrarian Courts, it is clear from Sec. 57 that the original and exclusive
jurisdiction to determine such cases is in the RTCs. Any effort to transfer such jurisdiction to the
adjudicators and to convert the original jurisdiction of the RTCs into appellate jurisdiction would be
contrary to Sec. 57 and therefore would be void. Thus, direct resort to the SAC by private respondent
is valid. It would be well to emphasize that the taking of property under RA No. 6657 is an exercise of
the power of eminent domain by the State. The valuation of property or determination of just
compensation in eminent domain proceedings is essentially a judicial function which is vested with
the courts and not with administrative agencies. Consequently, the SAC properly took cognizance of
respondent’s petition for determination of just compensation.