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    Mateo v. Dar

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    CHARMAINE KLAIRE ALONZO
    The Supreme Court ruled that the exception to the doctrine of exhaustion of administrative remedies applies in this case. While administrative remedies must generally be exhausted first, an exception exists when there is unreasonable delay or official inaction by the agency. In this case, the Department of Agrarian Reform took no action to conduct valuation proceedings for over 2 years after acquiring the landowners' property. This delay irretrievably prejudiced the landowners. Therefore, the landowners were justified in filing their compensation case directly with the court instead of waiting indefinitely for the agency to act.

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    Mateo v. Dar

    Uploaded by

    CHARMAINE KLAIRE ALONZO
    21 views3 pages
    The Supreme Court ruled that the exception to the doctrine of exhaustion of administrative remedies applies in this case. While administrative remedies must generally be exhausted first, an exception exists when there is unreasonable delay or official inaction by the agency. In this case, the Department of Agrarian Reform took no action to conduct valuation proceedings for over 2 years after acquiring the landowners' property. This delay irretrievably prejudiced the landowners. Therefore, the landowners were justified in filing their compensation case directly with the court instead of waiting indefinitely for the agency to act.

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    2. MATEO V. DAR

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    The Supreme Court ruled that the exception to the doctrine of exhaustion of administrative remedies applies in this case. While administrative remedies must generally be exhausted first, an exception exists when there is unreasonable delay or official inaction by the agency. In this case, the Department of Agrarian Reform took no action to conduct valuation proceedings for over 2 years after acquiring the landowners' property. This delay irretrievably prejudiced the landowners. Therefore, the landowners were justified in filing their compensation case directly with the court instead of waiting indefinitely for the agency to act.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    21 views3 pages

    Mateo v. Dar

    Uploaded by

    CHARMAINE KLAIRE ALONZO
    The Supreme Court ruled that the exception to the doctrine of exhaustion of administrative remedies applies in this case. While administrative remedies must generally be exhausted first, an exception exists when there is unreasonable delay or official inaction by the agency. In this case, the Department of Agrarian Reform took no action to conduct valuation proceedings for over 2 years after acquiring the landowners' property. This delay irretrievably prejudiced the landowners. Therefore, the landowners were justified in filing their compensation case directly with the court instead of waiting indefinitely for the agency to act.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 3

    MATEO V. DEPARTMENT OF AGRARIAN REFORM, et.al.

    G.R. No. 186339


    February 15, 2017
    REYES, J.
    THIRD DIVISION

    DOCTRINE:

    While the Court recognizes the primacy of the doctrine of exhaustion of administrative
    remedies in our judicial system, it bears emphasizing that the principle admits of
    exceptions, among which is when there is unreasonable delay or official inaction that
    irretrievably prejudices a complainant.

    LEGAL BASES:

     Section 50 of R.A. No. 6657 provides that the DAR is vested with ''primary
    jurisdiction to determine and adjudicate agrarian reform matters" and "exclusive
    original jurisdiction over all matters involving the implementation of agrarian
    reform" except those falling under the jurisdiction of the Department of
    Agriculture (DA) and the Department of Environment and Natural Resources.

     Section 57 confers "special" and "original and exclusive" jurisdiction to the SAC
    over all petitions of landowners for the determination of just compensation.

     In San Miguel Properties, Inc. v. Perez, the Court held that the doctrine of primary
    jurisdiction bas been increasingly called into play on matters demanding the
    special competence of administrative agencies even if such matters are at the
    same time within the jurisdiction of the courts. A case that requires for its
    determination the expertise, specialized skills, and knowledge of some
    administrative board or commission because it involves technical matters or
    intricate questions of fact, relief must first be obtained in an appropriate
    administrative proceeding before a remedy will be supplied by the courts
    although the matter comes within the jurisdiction of the courts. The application
    of the doctrine does not call for the dismissal of the case in the court but only for
    its suspension until after the matters within the competence of the administrative
    body are threshed out and determined.

    FACTS:

    The Mateos were the registered owners of coconut and rice lands with a total area of
    1,323,112 square meters situated at Fabrica, Bacon, Sorsogon and were covered by TCT
    No. T-22822. A portion of the lands was brought under the coverage of the CARP of the
    government. DAR entered the premises sometime in June 1994. LBP valued the land at
    ₱52,000.00 per hectare but, the Mateos rejected it.

    The Mateos filed a complaint against LBP, DAR and the farmer-beneficiaries for just
    compensation which was raffled to the SAC. The LBP and DAR filed their respective
    answers arguing that since no summary administrative proceedings to determine the
    amount of just compensation had been conducted yet, the complaint of the Mateos was
    premature.

    The SAC rendered judgment ordering LBP to pay the Mateos the amount of
    ₱71,143,623.00 as just compensation for 112.3112 hectares of coconut and rice lands
    subject property, after consideration of many factors and reports for the fair valuation
    of the land in Sorsogon.

    LBP appealed and argued that the complaint of the Mateos was premature and that the
    SAC failed to consider the guidelines provided for in Section 1718 of R.A. No. 6657 in
    determining just compensation. The Mateos sought the dismissal of the appeal.

    The CA rendered Decision setting aside the SAC's judgment and dismissing without
    prejudice the complaint of the Mateos ratiocinating that the latter prematurely filed with
    the court the complaint for determination of just compensation, thus failing to exhaust
    the prescribed administrative remedy and, in the process, preventing the DARAB from
    complying with the said administrative process which is mandatory.

    The Mateos filed a Motion for Reconsideration, which was denied by CA. Hence, the
    Mateos filed the petition for review.

    ISSUE:

    Whether or not the CA erred in negating the jurisdiction of the RTC, as a SAC, to
    determine in the first instance and in the absence of the conduct of prior administrative
    proceedings, questions of just compensation to be paid to landowners.

    RULING:

    Yes. While the Court recognizes the primacy of the doctrine of exhaustion of
    administrative remedies in our judicial system, it bears emphasizing that the principle
    admits of exceptions, among which is when there is unreasonable delay or official
    inaction that irretrievably prejudices a complainant.

    The doctrine of exhaustion of administrative remedies finds no application in the instant


    case where the DAR took no initiative and inordinately delayed the conduct of summary
    administrative proceedings, and where during the pendency of the case before the SAC,
    the DARAB rendered decisions affirming the LBP's prior valuations of the subject
    property.

    COMMENTS:

    The exception is present in this case where the LBP and the DAR entered the property
    of the Mateos sometime in 1994, but deposited cash and Agrarian Reform Bonds as
    payment therefor only on December 13, 1996 and February 11, 1997. The LBP and the
    DAR were indisputably aware that the Mateos rejected the price offered as just
    compensation for the subject property. Still, at the time the Mateos filed their suit before
    the SAC, no summary administrative proceeding was yet initiated by the DAR to make
    further valuation. The SAC even had to issue no less than three orders dated November
    12, 1997, January 7, 1998 and March 18, 1998 for the DAR to conduct the necessary
    proceedings. DAR’s delay and inaction had unjustly prejudiced the Mateos and
    precluding them from filing a complaint before the SAC shall result in an injustice,
    which the law never intends.

    SUBMITTED BY: CHARMAINE KLAIRE A. ALONZO

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