Navigating Land Acquisition Under the Comprehensive Agrarian Reform Program: Understanding Jurisdictional Limi

The Comprehensive Agrarian Reform Program (CARP) is a cornerstone of Philippine land reform, but its implementation is a maze of procedures, deadlines, and jurisdictional boundaries. A recent Supreme Court ruling serves as a stark reminder that landowners who disagree with the government's valuation of their property must follow the correct legal channels—or risk losing their right to challenge the amount entirely. The case of Marasigan v. Provincial Agrarian Reform Officer illustrates what happens when a landowner pursues the wrong remedy.

The Case at a Glance

Benito Marasigan, Jr. owned two parcels of land in San Juan, Batangas, covering a total of over 18 hectares. The Department of Agrarian Reform (DAR) placed portions of these lots under CARP coverage. When the Land Bank of the Philippines (LBP) valued the acquired areas at roughly P113,000, Marasigan rejected the offer. He failed to reply to the DAR's notice, prompting the Provincial Agrarian Reform Adjudicator (PARAD) to conduct summary administrative proceedings to determine just compensation. The PARAD upheld the LBP's valuation.

The Procedural Misstep

Dissatisfied, Marasigan appealed to the Department of Agrarian Reform Adjudication Board (DARAB), arguing that his property should not have been covered by CARP and that the proceedings were flawed. The DARAB dismissed his appeal for lack of jurisdiction. The Court of Appeals affirmed, and the Supreme Court agreed.

The core issue was not the merits of Marasigan's objections but his choice of forum. Under Section 16 of Republic Act No. 6657, the Comprehensive Agrarian Reform Law, a landowner who disagrees with the valuation in a summary proceeding must bring the matter to the proper court—specifically, a Regional Trial Court designated as a Special Agrarian Court (RTC-SAC)—for final determination of just compensation. The law gives the landowner only 15 days from receipt of the decision to file such an action.

Marasigan instead appealed to the DARAB, which had no authority to review the PARAD's valuation decision. Because he missed the 15-day window to file with the RTC-SAC, the PARAD's decision became final and executory. As the Court noted, failure to contest the valuation within the prescribed period is deemed a concurrence with the land valuation.

Where to Raise Coverage Objections

The Court also clarified that Marasigan's objections to the property's inclusion in CARP should have been raised elsewhere. Protests against CARP coverage or petitions to lift a notice of coverage fall under the jurisdiction of the DAR's Regional Director, not the adjudication board. This is a crucial distinction: questions about whether land is properly covered by agrarian reform are "agrarian law implementation" (ALI) matters, while disputes over the amount of just compensation are resolved through a different process.

The Role of the DARAB and the RTC-SAC

The decision underscores the division of labor between administrative agencies and the courts. The DAR, through its adjudicators, conducts the preliminary determination of land value. However, the final word on just compensation rests with the RTC-SAC, which has original and exclusive jurisdiction over such petitions. This structure ensures that the government's power of eminent domain is subject to judicial oversight.

Practical Takeaways

• Know your deadlines. A landowner who rejects the DAR's valuation has only 15 days from receipt of the decision to file an original action with the RTC-SAC. Missing this window makes the valuation final and binding.
• Use the right forum. Appeals from a PARAD's valuation decision go directly to the RTC-SAC, not to the DARAB. The DARAB has no jurisdiction to review these decisions.
• Separate your issues. Objections to the coverage of land under CARP are handled by the DAR Regional Director or the DAR Secretary, not by the adjudication board in a valuation case.
• Participate early. Landowners should actively respond to DAR notices and participate in field investigations to protect their rights, including retention rights.
• Seek timely legal advice. The complexity of agrarian reform procedures makes it essential to consult counsel immediately upon receiving notices from the DAR or LBP.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.