"x x x.
Finding no merit in the arguments raised by petitioner LBP, the Court denies the instant Rule 45 Petition. However, the third issue with respect to the just compensation for the excluded portion of respondents Montalvan’s lands deserves some consideration.
With respect to the first issue, petitioner LBP argues that respondents’ filing with the SAC of a separate Complaint for the determination of just compensation was premature and in violation of the doctrine of exhaustion of administrative remedies. Petitioner reasoned that the revaluation proceedings in the DARAB following respondents’ rejection of the initial DAR offer were still pending. The line of reasoning employed by petitioner is not novel and has since been discredited by jurisprudential precedents.
The SAC has been statutorily determined to have original and exclusive jurisdiction over all petitions for the determination of just compensation due to landowners under the CARP.[15] This legal principle has been upheld in a number of this Court’s decisions and has passed into the province of established doctrine in agrarian reform jurisprudence.[16] In fact, this Court has sustained the exclusive authority of the SAC over the DARAB, even in instances when no administrative proceedings were conducted in the DARAB.[17]
In LBP v. CA,[18] the Court affirmed the jurisdiction of the SAC (RTC-Cabanatuan City, Branch 23) in determining the just compensation due to Marcia E. Ramos for her expropriated ricelands, even though the proceedings in the DARAB were still continuing at the time she resorted to the direct filing of a Complaint with the SAC. This doctrine was reiterated in LBP v. Celada,[19] in which Leonila P. Celada was permitted to file a petition for judicial determination of just compensation with the SAC (RTC-Tagbilaran City), even if the summary administrative proceedings in the DARAB (Region VII-Cebu City) had just been initiated. It was not an error for the SAC to assume jurisdiction over the issue of just compensation despite the pendency of the DARAB proceedings, as thus ruled by the Court:
We do not agree with petitioner’s submission that the SAC erred in assuming jurisdiction over respondent’s petition for determination of just compensation despite the pendency of the administrative proceedings before the DARAB. 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 decisions. 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 R.A. 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.[20] (Emphasis supplied.)
These judicial precedents are directly applicable to the case at bar. That the DARAB proceedings are still pending is not a fatal defect that will oust the SAC from its original and exclusive jurisdiction over a petition for judicial determination of just compensation in an agrarian reform case. The DAR referral of the issue of valuation to the DARAB will not prevent respondents from asserting in the SAC their rights as landowners, especially since the function of fixing the award of just compensation is properly lodged with the trial court and is not an administrative undertaking.[21]
Neither can respondents’ failure to file a motion for reconsideration or an appeal from the Decision of the DARAB be considered as a grave and serious violation of the doctrine of exhaustion of administrative remedies. Such reasoning would ultimately deprive the SAC of the authority to hear and decide the matter of just compensation.
There is no inherent inconsistency between (a) the primary jurisdiction of the DAR to determine and adjudicate agrarian reform matters and exclusive original jurisdiction over all questions involving the implementation of agrarian reform, including those of just compensation; and (b) the original and exclusive jurisdiction of the SAC over all petitions for the determination of just compensation. “The first refers to administrative proceedings, while the second refers to judicial proceedings.”[22] The jurisdiction of the SAC 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.[23] In LBP v. Escandor,[24] the Court further made the following distinctions:
It is settled that the determination of just compensation is a judicial function. The DAR’s land valuation is only preliminary and is not, by any means, final and conclusive upon the landowner or any other interested party. In the exercise of their functions, the courts still have the final say on what the amount of just compensation will be.
Although the DAR is vested with primary jurisdiction under the Comprehensive Agrarian Reform Law (CARL) of 1988 to determine in a preliminary manner the reasonable compensation for lands taken under the CARP, such determination is subject to challenge in the courts. The CARL vests in the RTCs, sitting as SACs, original and exclusive jurisdiction over all petitions for the determination of just compensation. This means that the RTCs do not exercise mere appellate jurisdiction over just compensation disputes.
We have held that the jurisdiction of the RTCs is not any less “original and exclusive” because the question is first passed upon by the DAR. The proceedings before the RTC are not a continuation of the administrative determination. Indeed, although the law may provide that the decision of the DAR is final and unappealable, still a resort to the courts cannot be foreclosed on the theory that courts are the guarantors of the legality of administrative action.[25] (Emphasis supplied.)
Applied to the instant case, the mere fact that landowners, respondents herein, failed to avail themselves of a motion for reconsideration or of an appeal from an adverse Decision of the DARAB will not affect the jurisdiction of the SAC, which had already been exercising authority over the case prior to that adverse ruling. Not being a continuation of the administrative proceedings, the pending Complaint filed by respondents Montalvan in the judicial courts will not be foreclosed by the DARAB’s Decision.
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