Other Kinds of Jurisdiction:

12
LBP vs DALAUTA, 835 SCRA 1 (2017)
FACTS: Respondent Eugenio Dalauta (Dalauta) was the registered owner of an agricultural land in
Florida, Butuan City, with an area of 25.2160 hectares and covered by Transfer Certificate of Title (TCT)
No. T-1624. The land was placed by the Department of Agrarian Reform (DAR) under compulsory
acquisition of the Comprehensive Agrarian Reform Program (CARP) as reflected in the Notice of
Coverage, dated January 17, 1994, which Dalauta received on February 7, 1994. Petitioner Land Bank
of the Philippines (LBP) offered ₱192,782.59 as compensation for the land, but Dalauta rejected such
valuation for being too low.

The case was referred to the DAR Adjudication Board (DARAB) through the Provincial Agrarian Reform
Adjudicator (PARAD) of Butuan City. A summary administrative proceeding was conducted to
determine the appropriate just compensation for the subject property. In its Resolution, dated
December 4, 1995, the PARAD affirmed the valuation made by LBP in the amount of ₱192,782.59.

On February 28, 2000, Dalauta filed a petition for determination of just compensation with the RTC,
sitting as SAC. He alleged that LBP's valuation of the land was inconsistent with the rules and regulations
prescribed in DAR Administrative Order (A.O.) No. 06, series of 1992, for determining the just
compensation of lands covered by CARP's compulsory acquisition scheme.

During the trial, the SAC constituted the Board of Commissioners (Commissioners) tasked to inspect
the land and to make a report thereon. The Report of the Commissioners, dated July 10, 2002,
recommended that the value of the land be pegged at ₱100,000.00 per hectare. With both Dalauta and
the DAR objecting to the recommended valuation, the SAC allowed the parties to adduce evidence to
support their respective claims.

ISSUE: Whether or not the trial court had properly taken jurisdiction over the case despite the finality
of the PARAD Resolution.

HELD: Jurisdiction is defined as the power and authority of a court to hear, try and decide a case.
Jurisdiction over the subject matter is conferred only by the Constitution or the law. The courts, as well
as administrative bodies exercising quasi-judicial functions, have their respective jurisdiction as may be
granted by law. In connection with the courts' jurisdiction vis-a-vis jurisdiction of administrative bodies,
the doctrine of primary jurisdiction takes into play.

The doctrine of primary jurisdiction tells us that courts cannot, and will not, resolve a controversy
involving a question which is within the jurisdiction of an administrative tribunal, especially where the
question demands the exercise of sound administrative discretion requiring the special knowledge,
experience and services of the administrative tribunal to determine technical and intricate matters of
fact. In agrarian reform cases, primary jurisdiction is vested in the DAR, more specifically, in the DARAB.

WHEREFORE, the Court hereby DECLARES that the final determination of just compensation is a judicial
function; that the jurisdiction of the Regional Trial Court, sitting as Special Agrarian Court, is original
and exclusive, not appellate; that the action to file judicial determination of just compensation shall be
ten (10) years from the time of the taking; and that at the time of the filing of judicial determination,
there should be no pending administrative action for the determination of just compensation.
 Parties to Civil Action:
50
Enriquez Vda. De Santiago vs. Vilar, 857 SCRA 451 (2017)
FACTS:

Spouses Jose C. Zulueta and Soledad Ramos (Spouses Zulueta), registered owners of several parcels of
land covered by Transfer Certificate of Title (TCT) Nos. 26105, 37177 and 50356 (mother titles),
obtained various loans secured by the mother titles from the GSIS. The amount of loans, with the
accumulated value of P3,117,000.00 were obtained from September 1956 to October 1957.

From the records, the lot covered by Transfer Certificate of Title (TCT) No. 26105 was divided into 199
lots. Under the first mortgage contract, 78 of these lots were excluded from the mortgage.

When Spouses Zulueta defaulted in their payment, GSIS extra-judicially foreclosed the mortgages in
August 1974 wherein the latter emerged as the highest bidder. A certificate of sale was then issued.
GSIS, however, consolidated its title on all of the three mother titles, including the 78 lots which were
expressly excluded from the mortgage contract.

Later, GSIS sold the foreclosed properties to Yorkstown Development Corporation (YDC). The same,
however, was disapproved by the Office of the President. Accordingly, the TCTs issued in favor of YDC
were canceled.

When GSIS reacquired the properties sold to YDC, it began to dispose the foreclosed lots, including
those not covered by the foreclosure sale.

Thereafter, Spouses Zulueta were succeeded by Antonio Zulueta (Antonio), who transferred all his
rights and interests in the excluded lots to Eduardo Santiago (Eduardo). Claiming his rights and interests
over the excluded lots, Eduardo, through his counsel, sent a letter to GSIS for the return of the same.

In May 1990, Antonio, as represented by Eduardo, filed an Action for Reconveyance of the excluded
lots against the GSIS. Subsequently, Antonio was substituted by Eduardo. Upon Eduardo's demise,
however, he was substituted by his widow, herein petitioner Rosario.

RTC of Pasig City ordered GSIS to reconvey to Rosario the excluded lots or to pay the market value of
said lots in case reconveyance is not possible. The Pasig City RD was likewise ordered to cancel the titles
covering the excluded lots issued in the name of GSIS. CA affirmed the trial court's rulings.

ISSUE:

Whether or not the CA erred in impleading Vilar as party-plaintiff in substitution of Rosario.

HELD:

Both Rosario and GSIS claim that Rosario is an indispensable party in the petition because the same
seeks to assail the order of the RTC which involves its action on Vilar's motion to be substituted in
Rosario's stead as regards the implementation of the writ of execution.

The Court finds the same to be with merit.

The case stemmed from the action for reconveyance filed by Eduardo, husband of Rosario. To recall,
Eduardo was the successor-in-interest of Antonio, who is actually the successor-in-interest of Spouses
Zulueta. Spouses Zulueta are the original owners of the subject parcels of land. Upon the death of the
party-plaintiff Eduardo, Rosario was substituted in his stead. The case was subsequently decided on
December 17, 1997 and affirmed by this Court in October 28, 2003. An Entry of Judgment was issued
in 2004. In all these incidents, Rosario was considered as the party-plaintiff.

By definition, an indispensable party is a party-in-interest without whom no final determination can be

had of an action, and who shall be joined either as plaintiffs or defendants. It is a party whose interest
will be affected by the court's action in the litigation.

Verily, Rosario is an indispensable party in the petition before the CA as she is the widow of the original
party-plaintiff Eduardo. The determination of the propriety of the action of the trial court in merely
noting and not granting his motion would necessarily affect her interest in the subject matter of
litigation as the party-plaintiff.
Proof of Service:
88
Manotoc vs CA, 499 SCRA 21
FACTS: Petitioner is the defendant in a civil case, pro se, and on behalf of the Estate of Archimedes
Trajano v. Imelda ‘Imee’ R. Marcos-Manotoc for Filing, Recognition and/or Enforcement of Foreign
Judgment. Respondent Trajano seeks the enforcement of a foreign court’s judgment rendered on May
1, 1991 by the United States District Court of Honolulu, Hawaii, United States of America, in a case
entitled Agapita Trajano, et al. v. Imee Marcos-Manotoc a.k.a. Imee Marcos, Civil Case No. 86-0207 for
wrongful death of deceased Archimedes Trajano committed by military intelligence officials of the
Philippines allegedly under the command, direction, authority, supervision, tolerance, sufferance
and/or influence of defendant Manotoc, pursuant to the provisions of Rule 39 of the then Revised Rules
of Court. Based on paragraph two of the Complaint, the trial court issued a Summons addressed to
petitioner at Alexandra Homes, E2 Room 104, at No. 29 Meralco Avenue, Pasig City. The Summons and
a copy of the Complaint were allegedly served upon (Mr.) Macky de la Cruz, an alleged are taker of
petitioner at the condominium unit mentioned earlier. When petitioner failed to file her Answer, the
trial court declared her in default. Petitioner, filed a Motion to Dismiss on the ground of lack of
jurisdiction of the trial court over her person due to an invalid substituted service of summons. Trial
court rejected Manotoc’s Motion to Dismiss and relied on the presumption that the sheriff’s substituted
service was made in the regular performance of official duty, and such presumption stood in the
absence of proof to the contrary.

ISSUE: Whether or not the Substituted service was valid.

HELD: NO. Requirements for Substituted Service, Section 8 of Rule 14 of the old Revised Rules of Court
which applies to this case can be broken down to the following requirements:(1)Impossibility of Prompt
Personal Service (2)Specific Details in the Return (3)A Person of Suitable Age and Discretion (4)A
Competent Person in Charge A meticulous scrutiny of the aforementioned Return readily reveals the
absence of material data on the serious efforts to serve the Summons on petitioner Manotoc in person.
There is no clear valid reason cited in the Return why those efforts proved inadequate, to reach the
conclusion that personal service has become impossible or unattainable outside the generally couched
phrases of “on many occasions several attempts were made to serve the summons xxx personally,” “at
reasonable hours during the day,” and “to no avail for the reason that the said defendant is usually out
of her place and/or residence or premises.” Before resorting to substituted service, a plaintiff must
demonstrate an effort in good faith to locate the defendant through more direct means. Respondent
Trajano failed to demonstrate that there was strict compliance with the requirements of the then
Section 8, Rule 14 (now Section 7, Rule 14 of the 1997 Rules of Civil Procedure), the proceedings held
before the trial court perforce must be annulled.