The Supreme Court held that the Department of Agrarian Reform Adjudication Board (DARAB) does not have the power to issue writs of certiorari. Only courts of law can issue such writs, which are used to review the actions of lower tribunals. This ruling reinforces the separation of powers, preventing administrative agencies from overstepping their executive functions and encroaching on judicial authority, ensuring that jurisdictional errors are addressed by the appropriate judicial bodies.

Land Valuation Dispute: Can DARAB Issue Certiorari?

This case revolves around a disagreement over the just compensation for land acquired under the Comprehensive Agrarian Reform Program (CARP). Eliza Zoleta offered her land for sale to the government, but she rejected the Land Bank of the Philippines’ (Landbank) valuation. The Regional Agrarian Reform Adjudicator (RARAD) set a higher compensation, but Landbank challenged this in court. While that case was pending, the RARAD ordered the execution of the compensation order. Landbank then filed a petition for certiorari before the DARAB, questioning the RARAD’s order. The DARAB granted Landbank’s petition, which prompted Zoleta’s heirs to challenge DARAB’s authority to issue such a writ.

The central legal question before the Supreme Court was whether the DARAB has the power to issue writs of certiorari. The power to issue such writs is traditionally reserved for courts of law as an essential component of judicial review. The Supreme Court has consistently held that administrative agencies, like the DARAB, do not possess this power unless it is explicitly granted by the Constitution or a law. Here, no such explicit grant exists for DARAB. The DARAB is primarily an administrative body tasked with resolving agrarian disputes through its quasi-judicial powers, which are incidental to its executive functions.

The Court emphasized that the power to issue writs of certiorari is an inherent aspect of judicial power, which is constitutionally vested in the courts. This power allows higher courts to correct jurisdictional errors made by lower tribunals. To allow an administrative agency like DARAB to wield this power would blur the lines between the executive and judicial branches, undermining the principle of separation of powers. The Supreme Court anchored its ruling on the constitutional division of powers among the three branches of government: the Executive, the Legislative, and the Judiciary. Each branch has its defined sphere of authority, and one branch cannot encroach on the powers and duties of another.

The court acknowledged that administrative agencies, like the DARAB, possess quasi-judicial powers, which allow them to hear and determine questions of fact related to their administrative functions. However, these powers are limited to adjudicating rights incidental to the agency’s functions under the law. They do not extend to the exercise of judicial review, which involves interpreting laws and determining whether a government body acted without or in excess of its jurisdiction. The Supreme Court in Department of Agrarian Reform Adjudication Board v. Lubrica^[35] already settled this matter.

Jurisdiction, or the legal power to hear and determine a cause or causes of action, must exist as a matter of law. It is settled that the authority to issue writs of certiorari, prohibition, and mandamus involves the exercise of original jurisdiction which must be expressly conferred by the Constitution or by law. It is never derived by implication.

The historical context of the writ of certiorari further supports this interpretation. Originating in England, the writ was a prerogative of the King’s Bench, the highest court, to ensure that inferior tribunals acted within their jurisdiction. This power was later adopted in the United States and the Philippines, consistently as a function of the judiciary. The Supreme Court noted that allowing the DARAB to issue writs of certiorari would effectively transform it into a court of law, a role for which it was not created or equipped.

The Supreme Court then looked into the relevant laws governing the DARAB’s creation and functions, namely, Executive Order Nos. 229 and 129-A, and Republic Act No. 6657, also known as the Comprehensive Agrarian Reform Law of 1988. These laws vest the DARAB with quasi-judicial powers to resolve agrarian reform matters and grant it primary jurisdiction over the implementation of agrarian reform. However, none of these laws explicitly grant the DARAB the power to issue writs of certiorari. The Court found that the DARAB’s reliance on its own rules of procedure to justify its exercise of certiorari powers was misplaced. Procedural rules cannot expand an agency’s jurisdiction beyond what is granted by law.

That the statutes allowed the DARAB to adopt its own rules of procedure does not permit it with unbridled discretion to grant itself jurisdiction ordinarily conferred only by the Constitution or by law. Procedure, as distinguished from jurisdiction, is the means by which the power or authority of a court to hear and decide a class of cases is put into action. Rules of procedure are remedial in nature and not substantive. They cover only rules on pleadings and practice.

The Supreme Court also addressed Landbank’s procedural missteps in this case. Landbank initially sought to restrain the DARAB’s actions before the Special Agrarian Court but failed to implead the DARAB as a respondent. This oversight led to the denial of its plea. Subsequently, Landbank sought relief from the DARAB itself, requesting it to issue a writ of certiorari against its own RARAD. The Supreme Court found this approach to be flawed and emphasized that Landbank should have pursued the appropriate legal remedies in the proper forum, which is the regular courts.

The Court acknowledged the DARAB’s good intentions in attempting to rectify what it perceived as a breach of authority by the RARAD. However, it reiterated that such intentions cannot justify the exercise of powers that were not granted to it. The Supreme Court’s decision served as a reminder of the importance of adhering to the constitutional framework and respecting the boundaries between the different branches of government. It clarified that administrative agencies must operate within the limits of their statutory authority and cannot assume powers that are reserved for the judiciary.

FAQs

What was the key issue in this case?	The key issue was whether the Department of Agrarian Reform Adjudication Board (DARAB) has the authority to issue writs of certiorari, a power traditionally reserved for courts.
What is a writ of certiorari?	A writ of certiorari is a court order used to review the decisions of lower courts or tribunals, ensuring they acted within their jurisdiction and with proper procedure.
Why did Landbank file a petition for certiorari with the DARAB?	Landbank filed the petition to challenge an order and alias writ of execution issued by the Regional Agrarian Reform Adjudicator (RARAD), arguing it was issued improperly.
What was the Supreme Court’s ruling in this case?	The Supreme Court ruled that the DARAB does not have the power to issue writs of certiorari, as this power is reserved for courts of law.
What is the significance of the separation of powers in this case?	The separation of powers doctrine ensures that no single branch of government becomes too powerful; allowing DARAB to issue certiorari would infringe on judicial authority.
What are quasi-judicial powers?	Quasi-judicial powers are the powers of administrative agencies to hear and determine facts and make decisions, but these powers are limited and do not equate to full judicial authority.
What should Landbank have done instead of filing with DARAB?	Landbank should have sought recourse through the regular courts, which have the authority to issue writs of certiorari and review the RARAD’s actions.
How does this ruling affect agrarian disputes?	This ruling clarifies that parties seeking judicial review of agrarian rulings must turn to the courts, reinforcing the separation of powers and preventing administrative overreach.

This decision reinforces the constitutional separation of powers, clarifying that administrative agencies like the DARAB must operate within their defined statutory limits. This prevents potential overreach and ensures that judicial review remains the purview of the courts. Litigants in agrarian disputes must seek judicial remedies from the appropriate courts, rather than administrative bodies, to ensure their rights are properly adjudicated.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.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: HEIRS OF ELIZA Q. ZOLETA VS. LAND BANK OF THE PHILIPPINES AND DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD, G.R. No. 205128, August 09, 2017