Understanding the Limits of Quasi-Judicial Powers: The DARAB's Jurisdictional Boundaries

The Department of Agrarian Reform Adjudication Board (DARAB) plays a crucial role in resolving agrarian disputes. But how far do its powers actually go? In Land Bank of the Philippines v. Quilit (G.R. No. 194167, February 10, 2021), the Supreme Court reaffirmed a fundamental principle: the DARAB, being a quasi-judicial body, cannot exercise the power to issue writs of certiorari. This decision clarifies the boundaries of administrative jurisdiction and serves as an important reminder for parties involved in agrarian cases.

The Facts of the Case

The case began when Magdalena Quilit and Mauricio Laoyan filed a petition with the Regional Agrarian Reform Adjudicator (RARAD) to annul the sale and redeem two parcels of agricultural land in La Trinidad, Benguet. The properties were formerly owned by the Spouses Tolding, who had mortgaged them to the Land Bank of the Philippines (LBP). After foreclosure, LBP acquired the lots and was issued Transfer Certificates of Title.

The RARAD ruled in favor of Quilit and Laoyan, holding that they could exercise their right of redemption. LBP filed a Notice of Appeal, but the RARAD denied it for being filed late. The RARAD then issued a Writ of Execution, prompting LBP to file a Motion for Reconsideration, which was also denied.

The Issue Before the Court

LBP subsequently filed a Petition for Certiorari with the DARAB, relying on Section 3, Rule VIII of the 1994 DARAB New Rules of Procedure, which appeared to allow such petitions. However, the DARAB dismissed the petition, citing its limited jurisdiction. The central issue was whether the DARAB had the authority to hear petitions for certiorari against RARAD orders.

The Supreme Court's Ruling

The Supreme Court denied LBP's petition and affirmed the rulings of the DARAB and the Court of Appeals. The Court held that the DARAB, as a quasi-judicial agency, lacks jurisdiction over petitions for certiorari. This principle was first established in Department of Agrarian Reform Adjudication Board v. Lubrica (G.R. No. 159145, April 29, 2005) and later reinforced in Heirs of Zoleta v. Land Bank of the Philippines (G.R. No. 194167).

The Court explained that the power to issue writs of certiorari is inherently judicial. It involves reviewing whether a tribunal acted without or in excess of jurisdiction, or with grave abuse of discretion—a function that belongs exclusively to courts of law. As an administrative agency under the Executive branch, the DARAB cannot exercise this power, even if its own rules purport to grant it.

Why Procedural Rules Cannot Confer Jurisdiction

The Court emphasized that the DARAB's rule-making power does not allow it to grant itself jurisdiction that the Constitution or statutes do not provide. Rules of procedure are remedial in nature; they cannot expand the substantive jurisdiction of a quasi-judicial body. The 1994 DARAB New Rules of Procedure, which allowed petitions for certiorari, were deemed constitutionally infirm as they represented an "executive encroachment into the judiciary."

The Court also rejected LBP's argument that the Lubrica ruling should not apply retroactively to petitions filed before 2005. Since the rule granting certiorari powers was void from the start, it conferred no rights and afforded no protection to parties who relied on it.

Practical Takeaways

• Know the proper remedy: Decisions of the RARAD should be appealed through the proper appellate channels, not through a petition for certiorari with the DARAB.
• Act promptly: A party aggrieved by a RARAD order may file a special civil action for certiorari under Rule 65 of the Rules of Court with the Court of Appeals within 60 days from notice.
• File motions for reconsideration on time: Under the DARAB rules, a motion for reconsideration must be filed within five days from receipt of the order. Failure to do so may bar further remedies.
• Quasi-judicial bodies have limits: Administrative agencies can only exercise powers expressly granted by law. They cannot assume judicial functions, including the issuance of extraordinary writs.
• Seek timely legal advice: Given the complexity of jurisdictional rules, parties in agrarian disputes should consult counsel early to avoid missing critical deadlines.

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