Springfield Development Corporation, Inc. v. Presiding Judge, RTC, Misamis Oriental, Br. 40, Cagayan de Oro City

Springfield Development Corporation, Inc. v. Presiding Judge, RTC, Misamis Oriental, Br.
40, Cagayan de Oro City

6 February 2007 | Ponente: Austria-Martinez
Overview: A DARAB decision was appealed to the RTC for annulment but the RTC dismissed the appeal for lack of
jurisdiction. The Court held that the RTC has the power to annul judgments of inferior courts and quasi-judicial bodies of
equal ranking to such inferior courts but not those of courts and quasi-judicial bodies of equal ranking to the RTC.
Statement of the Case

- DARAB declared Springfield under the coverage of CARL and ordered it to pay the farmer-beneficiaries.
- RTC dismissed the case for lack of jurisdiction
- CA dismissed the action for lack of merit ruling that the RTC does not have jurisdiction to annul the DARAB
Decision because it is a co-equal body
Statement of Facts
Petra Piit previously owned a lot in Cagayan de Oro (CDO). A portion of this lot was sold to Springfield which then
developed the property into a subdivision called Mega Heights Subdivision
4 May 1990 DAR, through its Municipal Agrarian Reform Officer, issued a Notice of Coverage placing the property
under the coverage of RA 6657 or the Comprehensive Agrarian Reform Law (CARL) of 1988
o Piit opposed said coverage
27 August 1991 DARAB Provincial Adjudicator Salcedo declared the property as residential and not suitable for
agriculture
o The Regional Director filed a notice of appeal which Salcedo disallowed for being pro forma and frivolous
o The decision became final and executory and Springfield continued with the development of the property.
DAR Regional Director filed a petition for relied from judgment of the DARAB decision
5 October 1995 DARAB granted the petition
o It directed the Municipal Agrarian Reform Office to proceed with the documentation, acquisition, and
distribution of the property to the true and lawful beneficiaries.
22 May 1997 DARAB ordered the heir of Piit and Springfield o pay the farmer-beneficiaries P12,340,800.00
corresponding to the value of the property since the property has already been developed into a subdivision.
13 June 1997 - Springfield and the heirs of Piit filed with the RTC of CDO a petition for annulment of the DARAB
Decision dated October 5, 1995 and all its subsequent proceedings
o They contend that the DARAB decision was rendered without affording petitioners any notice and hearing.
25 June 1997 on motion by the farmer-beneficiaries, the RTC dismissed the case for lack of jurisdiction
2 July 1997 Springfield and Piit filed with the CA a special civil action for certiorari, mandamus, and prohibition
with prayer for the issuance of writ of preliminary injunction and/or TRO
o Alleged that the RTC committed grave abuse of discretion when it ruled that the annulment of judgment
filed before it is actually an action for certiorari in a different color
o Stated that what it sought before the RTC is an annulment of the DARAB Decision and not certiorari, as
the DARAB Decision is void ab initio for having been rendered without due process of law.
16 July 1998 CA dismissed the petition ruling that RTC does not have jurisdiction to annul the DARAB Decision
because it is a co-equal body
12 January 1999 CA ordered the elevation of the DARAB records before it declaring that it overlooked the fact
that Springfield and Piit likewise applied for a writ of prohibition against the enforcement of the DARAB decision
which they claim to be patently void.
23 February 2000 CA dismissed the MR without specifically resolving the issue regarding the writ of prohibition
Applicable Laws:
BP 129 or the Judiciary Reorganization Act of 1980.
Issues:
Does the RTC have jurisdiction to annul a final judgment of the DARAB? No. The RTC does not have the power to annul a
decision rendered by a court or quasi-judicial body of equal ranking.
Rationale
The petition for annulment of the DARAB decision was filed with the RTC on June 13, 1997, before the advent of the 1997
Rules of Civil Procedure, which took effect on July 1, 1997. Thus, the applicable law is B.P. Blg. 129 or the Judiciary
Reorganization Act of 1980, enacted on August 10, 1981.
Before BP 129, a CFI has the authority to annul a final and executory judgment rendered by another CFI or by another
branch of the same court. But in later cases, the Court held that the better policy, as a matter of comity or courteous
interaction between courts of first instance and the branches thereof, is for the annulment cases to be tried by the same
court or branch which heard the main action.
In Ngo Bun Tiong v. Sayo, the Court expressed that pursuant to the policy of judicial stability, the doctrine of non-interference
between concurrent and coordinate courts should be regarded as highly important in the administration of justice whereby
the judgment of a court of competent jurisdiction may not be opened, modified or vacated by any court of concurrent
jurisdiction.
With the introduction of BP 129, the rule on annulment of judgments was specifically provided in Section 9(2) which vested in
the then IAC the exclusive original jurisdiction over actions for annulment of judgments of RTCs. According to the Interim
Rules and Guidelines implementing B.P. Blg. 129, the quasi-judicial bodies whose decisions are exclusively appealable to
the CA are those, which under the law, R.A. No. 5434,24 or its enabling acts, are specifically appealable to the CA.
BP 129 does not specifically provide for any power of the RTC to annul judgments of quasi-judicial bodies. But in the case of
BF Northwest Homeowners Association, Inc. v. IAC, the Court held that RTCs have jurisdictions over action for annulment of
judgments of inferior courts and administrative or quasi-judicial bodies of equal ranking with such inferior courts.
DARAB is a a quasi-judicial body created by Executive Order Nos. 229 and 129-A. R.A. No. 6657 delineated its adjudicatory
powers and functions. The DARAB Revised Rules of Procedure adopted on December 26, 1988 specifically provides for the
manner of judicial review of its decisions, orders, rulings, or awards. Rule XIV, Section 1 states:
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.
Further, the prevailing 1997 Rules of Civil Procedure, as amended, expressly provides for an appeal from the DARAB
decisions to the CA.
The rule is that where legislation provides for an appeal from decisions of certain administrative bodies to the CA, it means
that such bodies are co-equal with the RTC, in terms of rank and stature, and logically, beyond the control of the latter.
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 as the RTC does not have any jurisdiction to entertain the same.
Related issue: WON the petition for annulment of the DARAB judgment could be brought to the CA.
No. BP 129 vested CA the exclusive original jurisdiction over actions for annulment of judgments but only those rendered by
the RTC. It does not expressly give the CA the power to annul judgments of quasi-judicial bodies. Also, previous decisions
held that the silence of B.P. Blg. 129 on the jurisdiction of the CA to annul judgments or final orders and resolutions of quasi-
judicial bodies like the DARAB indicates its lack of such authority.
Judgment: The petition is PARTLY GRANTED and is remanded to the CA which is directed to resolve the prayer for the
issuance of the writ of prohibition.
Notes:

Springfield Development Corporation, Inc. v. Presiding Judge, RTC, Misamis Oriental, Br. 40, Cagayan de Oro City

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Springfield Development Corporation, Inc. v. Presiding Judge, RTC, Misamis Oriental, Br.

40, Cagayan de Oro City

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