 2 July 1997 – Springfield and Piit filed with the CA a special civil action for

4.SPRINGFIELD V RTC JUDGE certiorari, mandamus, and prohibition with prayer for the issuance of writ
GR NO. 142628 of preliminary injunction and/or TRO
FEBRUARY 6, 2007 o Alleged that the RTC committed grave abuse of discretion when
Topic: Jurisdiction it ruled that the annulment of judgment filed before it is
Petitioners: Springfield Development Corp Inc. actually an action for certiorari in a different color
Respondents: RTC Judge o Stated that what it sought before the RTC is an annulment of
Ponente: Austria-Martinez the DARAB Decision and not certiorari, as the DARAB Decision is
void ab initio for having been rendered without due process of
RECIT-READY/SUMMARY: A DARAB decision was appealed to the RTC for
law.
annulment but the RTC dismissed the appeal for lack of jurisdiction. The Court held
that the RTC has the power to annul judgments of inferior courts and quasi-judicial  16 July 1998 – CA dismissed the petition ruling that RTC does not have
jurisdiction to annul the DARAB Decision because it is a co-equal body
bodies of equal ranking to such inferior courts but not those of courts and quasi-
judicial bodies of equal ranking to the RTC.  12 January 1999 – CA ordered the elevation of the DARAB records before
it declaring that it overlooked the fact that Springfield and Piit likewise
FACTS:
applied for a writ of prohibition against the enforcement of the DARAB
 Petra Piit previously owned a lot in Cagayan de Oro (CDO). A portion of
decision which they claim to be patently void.
this lot was sold to Springfield which then developed the property into a
 23 February 2000 – CA dismissed the MR without specifically resolving
subdivision called Mega Heights Subdivision
the issue regarding the writ of prohibition
 4 May 1990 – DAR, through its Municipal Agrarian Reform Officer, issued
a Notice of Coverage placing the property under the coverage of RA 6657
ISSUE:
or the Comprehensive Agrarian Reform Law (CARL) of 1988
 Does the RTC have jurisdiction to annul a final judgment of the DARAB?
 27 August 1991 – DARAB Provincial Adjudicator Salcedo declared the
o No. The RTC does not have the power to annul a decision rendered
property as residential and not suitable for agriculture.
by a court or quasi-judicial body of equal ranking.
 DAR Regional Director filed a petition for relied from judgment of the
DARAB decision
HELD/RATIO:
 5 October 1995 – DARAB granted the petition
 The petition for annulment of the DARAB decision was filed with the RTC on
o It directed the Municipal Agrarian Reform Office to proceed
June 13, 1997, before the advent of the 1997 Rules of Civil Procedure, which
with the documentation, acquisition, and distribution of the
took effect on July 1, 1997. Thus, the applicable law is B.P. Blg.129 or the
property to the true and lawful beneficiaries.
Judiciary Reorganization Act of 1980, enacted on August 10, 1981.
 22 May 1997 – DARAB ordered the heir of Piit and Springfield to pay the
o Before BP 129, a CFI has the authority to annul a final and executory
farmer-beneficiaries P12,340,800.00 corresponding to the value of the
judgment rendered by another CFI or by another branch of the same
property since the property has already been developed into a
court. But in later cases, the Court held that the better policy, as a
subdivision.
matter of comity or courteous interaction between courts of first
 13 June 1997 - Springfield and the heirs of Piit filed with the RTC of CDO a instance and the branches thereof, is for the annulment cases to be
petition for annulment of the DARAB Decision dated October 5, 1995 and
tried by the same court or branch which heard the main action.
all its subsequent proceedings
 With the introduction of BP 129, the rule on annulment of judgments was
o They contend that the DARAB decision was rendered without
specifically provided in Section 9(2) which vested in the then IAC the exclusive
affording petitioners any notice and hearing.
original jurisdiction over actions for annulment of judgments of RTCs.
 25 June 1997 – on motion by the farmer-beneficiaries, the RTC
 According to the Interim Rules and Guidelines implementing B.P. Blg. 129, the
dismissed the case for lack of jurisdiction
quasi-judicial bodies whose decisions are exclusively appealable to the CA are
those, which under the law, R.A. No. 5434,2 or its enabling acts, are specifically
appealable to the CA.
 BP 129 does not specifically provide for any power of the RTC to annul
judgments of quasi-judicial bodies. But in the case of BF Northwest
Homeowners Association, Inc. v. IAC, the Court held that RTCs have
jurisdictions over action for annulment of judgments of inferior courts and
administrative or quasi-judicial bodies of equal ranking with such inferior
courts.
 DARAB is a a quasi-judicial body created by Executive Order Nos. 229 and
129-A. R.A. No. 6657 allocated its adjudicatory powers and functions.
o The rule is that where legislation provides for an appeal from
decisions of certain administrative bodies to the CA, it means that
such bodies are co-equal with the RTC, in terms of rank and stature,
and logically, beyond the control of the latter.
 Given that DARAB decisions are appealable to the CA, the inevitable
conclusion is that the DARAB is a co-equal body with the RTC and its
decisions are beyond the RTC's control.

Judgment: The petition is PARTLY GRANTED and is remanded to the CA which

is directed to resolve the prayer for the issuance of the writ of prohibition.