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Department Of Agrarian Reform vs. Trinidad Valley Realty & Devt. Corp.

G.R. No. 173386, February 11, 2014

Facts: Trinidad Valley Realty and Development Corporation, et al. are the registered
owners of a parcel of land in Vallehermoso, Negros Oriental devoted to the
cultivation of sugar cane. A portion of this land was awarded by respondent, DAR to
beneficiaries of the Comprehensive Agrarian Reform Program. Trinidad opposed this
move in the RTC and alleged that: DAR committed grave abuse of discretion
amounting to lack or excess of jurisdiction, the valuation by Land Bank is not just
compensation, the register of deeds cannot cancel their title without a court order, and
that Land Bank together with the LRA and Register of deeds committed grave abuse of
discretion when they cooperated to commit the act. In its answer, DAR asserted that
jurisdiction over all matters concerning agrarian reform exclusively belongs to
DAR and that the RTC’s jurisdiction in agrarian reform matters is limited only to the
determination of just compensation and prosecution of all criminal offenses
under RA 6657. The RTC ruled in favor of Trinidad claiming that it has
jurisdiction. On appeal, the CA set aside the lower court’s decision citing that the RTC
has no jurisdiction over the said case hence this petition.

Issue: Whether the RTC has jurisdiction over the case at bar.

Held: No. In view of Section 54 of RA 6657; the RTC committed grave

abuse of discretion in admitting the amended petition as it did not have jurisdiction over
both the petition and amended petition filed by Trinidad et al. which clearly provides that
it is the CA, and not the RTC, which has jurisdiction over the case. It is a cardinal principle
in remedial law that the jurisdiction of a court over the subject matter of an action is
determined by the law in force at the time of the filing of the complaint and the allegations
of the complaint. Jurisdiction is determined exclusively by the Constitution and the law
and cannot be conferred by the voluntary act or agreement of the parties. It cannot also
be acquired through or waived, enlarged or diminished by their act or omission, nor
conferred by the acquiescence of the court. It is neither for the court nor the parties
to violate or disregard the rule, this matter being legislative in character. The
nature of an action, as well as which court or body has jurisdiction over it, is determined
based on the allegations contained in the complaint of the plaintiff, irrespective of
whether or not the plaintiff is entitled to recover upon all or some of the claims
asserted therein. The averments in the complaint and the character of the relief
sought are the ones to be consulted. Once vested by the allegations in the
complaint, jurisdiction also remains vested irrespective of whether or not the plaintiff
is entitled to recover upon all or some of the claims asserted therein. Section 54 of RA
6657 leaves no room for doubt that decisions, orders, awards or rulings of the DAR
may be brought to the CA by certiorari and not with the RTC through an ordinary
action for cancellation of title. The findings of fact of the DAR shall be final and conclusive
if based on substantial evidence. The Court likewise ruled in the similar case of DAR v.
Cuenca that "[a]ll controversies on the implementation of the Comprehensive
Agrarian Reform Program (CARP) fall under the jurisdiction of the Department
of Agrarian Reform (DAR), even though they raise questions that are also
legal or constitutional in nature." Given our ruling that the RTC lacked jurisdiction over
the instant case, we find no necessity to address the other issues raised in
the three consolidated petitions. The petition is denied.