G.R. No. 204232 , October 16, 2019
The Local Government of Sta. Cruz, Davao del Sur, as represented by its Municipal Mayor, Atty. Joel Ray L. Lopez, Petitioner, v. Provincial Office of the Department of Agrarian Reform, Digos City, Davao del Sur, Respondent.

FACTS

The Local Government Unit (LGU) of Sta. Cruz, Davao del Sur, filed a Petition for Injunction directly with the Supreme Court against the Provincial Office of the Department of Agrarian Reform (DAR). The petition sought to prevent the DAR from subjecting the Tan Kim Kee Estate, a 220-hectare property, under the coverage of the Comprehensive Agrarian Reform Program (CARP). The LGU had classified the estate as an industrial zone through its approved Municipal Comprehensive Development Plan/Land Use Plan and Zoning Ordinances for 1991-2000 and 2000-2012, envisioning it as an export processing zone to support agro-industrial programs. The landowners of the estate had previously filed an application for conversion to commercial/industrial use, which the DAR granted with a five-year development condition, later extended. Before the period lapsed, the landowners applied for exclusion from CARP coverage, claiming the land was used for cattle raising. In 2012, the DAR placed the estate under CARP coverage and, in a 2013 Order, denied the application for exclusion. The LGU argued that CARP coverage would undermine its economic development plans and cause irreparable damage, while the DAR maintained the coverage was valid due to the landowners’ failure to implement the conversion plan within the granted period.

ISSUE

Whether the reclassification of the Tan Kim Kee Estate as an industrial land by the LGU removes it from the coverage of the Comprehensive Agrarian Reform Law.

RULING

The Supreme Court DENIED the petition. The Court ruled that the LGU’s direct resort to the Supreme Court was improper, as the doctrine of hierarchy of courts requires that petitions for certiorari against DAR decisions be filed with the Court of Appeals, as explicitly provided under Section 54 of the CARL. While the Supreme Court and the Court of Appeals have concurrent jurisdiction to issue injunctive writs against agencies implementing CARP, the principle of hierarchy of courts applies, and none of the recognized exceptions to this principle were present in this case. The LGU’s speculative claims about the benefits of industrial zoning did not constitute a genuine constitutional issue or a matter of transcendental importance. Furthermore, the petition failed to state a cause of action because the LGU was not the registered owner of the estate and thus not a real party-in-interest; its perceived benefit from the estate’s development was a mere expectancy, not a present and substantial interest. Due to these procedural infirmities, the Court denied the petition.