Land Bank of the Philippines v. Eusebio, Jr. (G.R. No. 160143)


Respondent Eusebio, Jr., owner of a 790.4-hectare parcel of land situated in Masbate, voluntarily offered to sell his land to the government through the Department of Agrarian Reform for P19.5 million. DAR offered to purchase the land for P3 million but it was rejected by respondent. Petitioner Land Bank made a revaluation of the land but was rejected again by respondent. Meanwhile, LBP opened a trust account in favor of Eusebio, and then the DAR immediately took physical possession of the property, had the TCT cancelled in favor of the Republic of the Philippines, and distributed the property to the farmer-beneficiaries. The parties then referred the determination of just compensation with the DARAB. Respondent still finding the valuation unacceptable, filed before the RTC-Special Agrarian Court an action for determination and payment of just compensation against DAR and LBP. During trial, separate valuation reports were submitted, with the DAR and LBP using the guidelines/formula under RA 6657 in their computation. In its judgment, the RTC-SAC brushed aside the valuations fixed by DAR and LBP, and found instead as considerable just compensation the amount (P25 million) prayed for by respondent. Both parties appealed, but CA affirmed the judgment in toto.


Whether the RTC-SAC committed grave abuse of discretion in the determination of just compensation for the property.

Ruling: YES.

The determination of just compensation is essentially a judicial function that the Courts exercise within the parameters of the law; the RTC-SAC’s valuation in this case is erroneous for having been rendered outside the contemplation of the law.

In the exercise of the essentially judicial function of determining just compensation, the RTC-SAC is not granted unlimited discretion. It must consider and apply the R.A. No. 6657-enumerated factors and the DAR formula (that reflects these factors) as they provide the uniform framework or structure by which just compensation for property subject to agrarian reform should be determined.

A determination of just compensation based merely on “conscience” – a consideration entirely outside the contemplation of the law – is the precise situation that we find in this case. To be clear, other than in “conscience,” the RTC-SAC did not point to any particular consideration that impelled it to set the just compensation at ₱25 million. In fact, a reading of the RTC-SAC’s decision reveals a marked absence of any grounds by which it anchored its determination, more so of any explanation why it fixed the amount of ₱25 million. This marked absence of basis, taken together with these other considerations, convinced us that the RTC-SAC completely, even arbitrarily, relied on the amount that respondent prayed for in their complaint in fixing the property’s just compensation. This blind reliance on respondent’s prayer and the utter disregard of the prescribed factors and formula clearly amount to grave abuse of discretion for having been taken outside the contemplation of the law.

Thus, we set aside, as grave abuse of discretion, the just compensation of ₱25 million that the RTC-SAC fixed for Eusebio’s property. Accordingly, we likewise set aside, for grave error, the CA’s decision that affirmed in toto this RTC-SAC’s valuation.


Tomawis v. Balindong (G.R. No. 182434)


Respondents herein, daughters of the late Acraman Radia, filed with the Shari’a District Court an action for quieting of title of a parcel of land against petitioner Tomawis, alleging that they are the absolute owners of the lot, that petitioner assumed ownership of the land and removed the small houses they built therein, and thereby unlawfully deprived them of their possession of the land. Petitioner moved to dismiss the complaint assailing SDC’s lack of jurisdiction over the subject matter of the case, as it is the regular civil courts that had such jurisdiction pursuant to BP 129. Respondent judge denied the motion asserting in his decision SDC’s original jurisdiction over the case, concurrently with the RTC. Petitioner sought relief before the CA, but the latter dismissed the petition. Petitioner now asserts that BP 129 as amended, vesting original exclusive jurisdiction to the RTCs/MTCs over real actions, effectively removed the concurrent jurisdiction once pertaining to the SDC.


Whether the Shari’a District Court has jurisdiction over the action for quieting of title, notwithstanding the jurisdiction of RTCs or MTCs over such cases.

Ruling: YES.

The allegations, as well as the relief sought by private respondents, the elimination of the “cloud of doubts on the title of ownership” on the subject land, are within the SDC’s jurisdiction to grant.

A reading of the pertinent provisions of BP 129 and PD 1083 shows that the former, a law of general application to civil courts, has no application to, and does not repeal, the provisions found in PD 1083, a special law, which only refers to Shari’a courts. BP 129 was enacted to reorganize only existing civil courts and is a law of general application to the judiciary. In contrast, PD 1083 is a special law that only applies to Shari’a courts.

We have held that a general law and a special law on the same subject are statutes in pari materia and should be read together and harmonized, if possible, with a view to giving effect to both. A general law does not nullify a special law. The general law will yield to the special law in the specific and particular subject embraced in the latter. We must read and construe BP 129 and PD 1083 together, then by taking PD 1083 as an exception to the general law to reconcile the two laws.

In order to give effect to both laws at hand, we must continue to recognize the concurrent jurisdiction enjoyed by SDCs with that of RTCs under PD 1083.

We hold that the respondent court did not commit any grave abuse of discretion. Its reliance on the provisions of PD 1083 in asserting its jurisdiction was sound and unassailable.

Guy v. Ignacio (G.R. No. 167824)


Respondent Atty. Ignacio filed a complaint for blacklisting and deportation of herein petitioners-sisters, Geraldine and Grace, before the Bureau of Immigration on the basis that they are Canadian citizens illegally working in the Philippines. Acting on the complaint, the Special Prosecutor of the BI Commissioner issued a subpoena directing petitioners to appear before the Commission and to bring pertinent documents relating to their current immigration status, to which petitioners objected. Thus, the Board of Commissioners charged petitioners of violating Philippine Immigration Laws. As a remedy, petitioners applied for TRO with RTC Manila, which the latter granted enjoining respondents from further continuing with the deportation proceedings. However, on respondents’ recourse to CA, the latter annulled the writ of injunction relying its decision on the doctrine of primary jurisdiction.


Whether the RTC Manila has jurisdiction to issue an injunction notwithstanding the doctrine of primary jurisdiction.

Ruling: YES.                                                    

It is beyond cavil that the Bureau of Immigration has the exclusive authority and jurisdiction to try and hear cases against an alleged alien, and in the process, determine also their citizenship. And a mere claim of citizenship cannot operate to divest the Board of Commissioners of its jurisdiction in deportation proceedings. However, the rule enunciated above admits of an exception, at least insofar as deportation proceedings are concerned. In Chua Hiong vs. Deportation Board, the Court ruled:

When the evidence submitted by a respondent is conclusive of his citizenship, the right to immediate review should also be recognized and the courts should promptly enjoin the deportation proceedings.

The doctrine of primary jurisdiction of petitioners Board of Commissioners over deportation proceedings is, therefore, not without exception. Judicial intervention, however, should be granted in cases where the claim of citizenship is so substantial that there are reasonable grounds to believe that the claim is correct. In other words, the remedy should be allowed only on sound discretion of a competent court in a proper proceeding.

The present case, as correctly pointed out by petitioners and wrongfully found by the CA, falls within the above-cited exception considering that proof of their Philippine citizenship had been adduced, such as, the identification numbers issued by the Bureau of Immigration confirming their Philippine citizenship, they have duly exercised and enjoyed all the rights and privileges exclusively accorded to Filipino citizens, i.e., their Philippine passports issued by the Department of Foreign Affairs.

Umbao v. Yap (G.R. No. L-8933)


Petitioner Umbao and respondent Yap both had agreed in writing to “submit their case to the Wage Administration Service for investigation” and “to abide by whatever decision (said) office may render on the case” which “they recognized . . . to be final and conclusive.” After proper investigation had been conducted by Severo Puncan of the same Service, who after hearing the parties and considering their evidence, declared in a written report, respondent Yap to be liable for unpaid wages; that the award had been approved by Ruben Santos, Acting Chief of the Service; and that respondent had refused to abide by and comply with it.  Respondent’s answer did not deny the existence of the covenant and of the award but questioned the enforceability of both, contending mainly that the Service had no legal authority to act as arbitrator, that the procedural requirements of Republic Act No. 602 had not been followed, and that the provisions of Republic Act No. 876 known as the Arbitration Law had been disregarded. Petitioner then asked for judgment on the pleadings. The Court, noting non-observance of the procedure outlined in Republic Act No. 876, gave judgment for defendant. However upon motion to reconsider, the judge seeing differently, held the arbitration agreements to be a contract obligatory on the parties under the provisions of the New Civil Code. Consequently, he rendered judgment against defendant. Hence this appeal.


Whether or not the arbitration by the Service conformed with the Act.


The argument evidently assumes that a compromise agreement is the same as an arbitration agreement. Such assumption is error: one is different from the other; they are treated in two separate chapters of the Code.

No rules have been promulgated by this Court. However the Legislature adopted such rules in Republic Act No. 876 known as “The Arbitration Law’ effective December 1953. Said act was obviously adopted to supplement-not to supplant-the New Civil Code on arbitration. It expressly declares that “the provisions of chapters one and two, Title XIV, Book of the Civil Code the parties may select the arbitrator without court intervention. And section 8 of the Act impliedly permits them to do so. There is nothing in Republic Act 876 requiring court permission of knowledge or intervention before the arbitrator selected by the parties may perform his assigned work. The section does not mean there can be no arbitration without a previous court actuation.

The case between herein litigants has not required court intervention from the beginning, because they had named the arbitrator: the Administration Service and necessarily the proper officer, thereof, Severo Puncan. And this defendant should not be permitted to question the authority of said officer now, because he voluntarily submitted his evidence to him; and he only turned around to deny such authority when the resultant verdict adversely affected his pocket. He even appealed to the Secretary of Labor, and without questioning Puncan’s authority, pleaded for exoneration on the merits.

As to the arbitration proceedings, Republic Act No. 876 contains provisions about the procedure to be adopted by arbitrators, their oath, the hearings, and the form and content of the award. Even so, herein appellant asserted no prejudicial departure therefrom. As already stated, Republic Act No. 876 did not require court intervention (in the case at bar) prior to the award of the arbitrator, no ground for it having arisen, as the parties voluntarily took steps to carry out the settlement process down to the arbiter’s decision. It was only after such award, when defendant refused to comply that judicial action became necessary, thru the means afforded by the statute: confirmation of award and judgment.

These provisions, we believe, apply whether or not the court intervened from the very beginning. Now then, examining the complaint and the judgment entered herein in the light of the above directions, we find substantial conformity therewith; so much so that defendant raised no issue on the same.

Wherefore, the judgment should be, and is hereby affirmed.

Chung Fu Industries v. CA (G.R. No. 96283)


Petitioner Chung Fu Industries (Philippines) and private respondent Roblecor Philippines, Inc. forged a construction agreement whereby respondent contractor committed to construct and finish petitioner corporation’s industrial/factory complex. In the event of disputes arising from the performance of subject contract, it was stipulated therein that the issue(s) shall be submitted for resolution before a single arbitrator chosen by both parties. Roblecor filed a petition for Compulsory Arbitration with prayer for Temporary Restraining Order before respondent RTC to claim the unsatisfied account and unpaid progress billings. Chung Fu moved to dismiss the petition and further prayed for the quashing of the restraining order. Subsequent negotiations between the parties eventually led to the formulation of an arbitration agreement which, among others, provides: The parties mutually agree that the decision of the arbitrator shall be final and unappealable. Therefore, there shall be no further judicial recourse if either party disagrees with the whole or any part of the arbitrator’s award. Respondent RTC approved the arbitration agreement and thereafter, Engr. Willardo Asuncion was appointed as the sole arbitrator. Arbitrator Asuncion ordered petitioner to immediately pay respondent contractor and further declared the award as final and unappealable. Roblecor then moved for the confirmation of said award which was accordingly confirmed and a writ of execution granted to it. Meanwhile, Chung Fu moved to remand the case for further hearing and asked for a reconsideration of the judgment award claiming that Arbitrator Asuncion committed twelve (12) instances of grave error by disregarding the provisions of the parties’ contract. Chung Fu’s Motion was denied and similarly its motion for reconsiderationn. Chung Fu elevated the case via a petition for certiorari to respondent CA. The respondent appellate court concurred with the findings and conclusions of respondent trial court. A motion for reconsideration of said resolution was filed by petitioner, but was similarly denied.


Whether or not petitioners are estopped from questioning the arbitration award allegedly in view of the stipulations in the parties’ arbitration agreement that “the decision of the arbitrator shall be final and unappealable” and that “there shall be no further judicial recourse if either party disagrees with the whole or any part of the arbitrator’s award.”


We rule in the negative. It is stated explicitly under Art. 2044 of the Civil Code that the finality of the arbitrators’ award is not absolute and without exceptions. Where the conditions described in Articles 2038, 2039 and 2040 applicable to both compromises and arbitrations are obtaining, the arbitrators’ award may be annulled or rescinded. Additionally, under Sections 24 and 25 of the Arbitration Law, there are grounds for vacating, modifying or rescinding an arbitrator’s award. Thus, if and when the factual circumstances referred to in the above-cited provisions are present, judicial review of the award is properly warranted.

This is where the proper remedy is certiorari under Rule 65 of the Revised Rules of Court. It is to be borne in mind, however, that this action will lie only where a grave abuse of discretion or an act without or in excess of jurisdiction on the part of the voluntary arbitrator is clearly shown. It should be stressed, too, that voluntary arbitrators, by the nature of their functions, act in a quasi-judicial capacity. It stands to reason, therefore, that their decisions should not be beyond the scope of the power of judicial review of this Court.

In the case at bar, petitioners assailed the arbitral award on the following grounds, most of which allege error on the part of the arbitrator in granting compensation for various items which apparently are disputed by said petitioners. After closely studying the list of errors, as well as petitioners’ discussion of the same in their Motion to Remand Case For Further Hearing and Reconsideration and Opposition to Motion for Confirmation of Award, we find that petitioners have amply made out a case where the voluntary arbitrator failed to apply the terms and provisions of the Construction Agreement which forms part of the law applicable as between the parties, thus committing a grave abuse of discretion. Furthermore, in granting unjustified extra compensation to respondent for several items, he exceeded his powers — all of which would have constituted ground for vacating the award under Section 24 (d) of the Arbitration Law.

Wherefore, the petition is granted. The Resolutions of the CA as well as the Orders of respondent RTC are hereby SET ASIDE. Accordingly, this case is REMANDED to the court of origin for further hearing on this matter. All incidents arising therefrom are reverted to the status quo ante until such time as the trial court shall have passed upon the merits of this case.