c. Special Agrarian Courts

Special Agrarian Courts

Concept

A Special Agrarian Court (SAC) is a designated branch of the Regional Trial Court (RTC), not a separate court. Its judges exercise special agrarian jurisdiction in addition to the regular jurisdiction of their respective courts. (Sec. 56, Rep. Act No. 6657)¹

Governing provisions

The Supreme Court must designate at least one RTC branch in each province as an SAC and may designate additional branches as the number of agrarian cases requires. SACs retain the powers and prerogatives of RTCs. More generally, the Supreme Court may designate RTC branches to handle agrarian cases in the interest of speedy and efficient administration of justice. (Sec. 56, Rep. Act No. 6657)¹ (Sec. 23, Batas Pambansa Blg. 129)²

Requisites / Rules

• In designating SACs, the Supreme Court gives preference to RTCs already assigned agrarian cases or whose presiding judges formerly served in the defunct Court of Agrarian Relations. (Sec. 56, Rep. Act No. 6657)¹
• An SAC may, on its own initiative or on a party’s request, appoint one or more commissioners to examine relevant facts, including property valuation, and submit a written report. (Sec. 58, Rep. Act No. 6657)³
• No SAC order on an issue or incident raised before it may be elevated to the appellate courts until the hearing has ended and the case has been decided on the merits. (Sec. 59, Rep. Act No. 6657)⁴

Distinctions

Administrative valuation is preliminary, while the final determination of just compensation is a judicial function. The RTC sitting as an SAC has original and exclusive jurisdiction to make that determination; DARAB procedural rules cannot convert that jurisdiction into appellate jurisdiction. (Land Bank of the Philippines v. Franco, G.R. No. 203242, 12 March 2019)⁵ (Limkaichong v. Land Bank of the Philippines, G.R. No. 158464, 2 August 2016)⁶

Not every controversy involving agricultural land belongs before an agrarian adjudicator. In a tenancy or agricultural-leasehold claim, the elements supporting DARAB jurisdiction must be established. Where only the agricultural-land element was present, the dispute was one of private rights for the RTC. (Lim v. Cruz, G.R. No. 248650, 15 March 2023)⁷

Key doctrines

Just compensation must rest on evidence establishing the figures used in valuation. Where the record is inadequate, remand to the trial court for reception of evidence and recomputation is appropriate; an appellate court should not itself resolve the missing factual matters. (Land Bank of the Philippines v. Spouses Cortez, G.R. No. 210422, 7 September 2022)⁸ (Land Bank of the Philippines v. Corporation, G.R. No. 217137, 16 January 2023)⁹

Exceptions

The cited decisions address the effect of the DARAB 15-day period differently. Dalauta held that a late petition challenging a PARAD determination was barred by the period and the resolution’s finality. Limkaichong held that dismissal solely for filing beyond that period was improper in light of the SAC’s original and exclusive jurisdiction. Do not treat either holding as eliminating the distinction without examining the applicable facts and procedural posture. (Land Bank of the Philippines v. Dalauta, G.R. No. 190004, 8 August 2017)¹⁰ (Limkaichong v. Land Bank of the Philippines)⁶

Bar tip

Identify the RTC branch’s SAC designation, then separate judicial fixing of just compensation from an asserted tenancy dispute. If agrarian character is alleged and a party is a farmer, farmworker, or tenant, consider the required referral to the DAR for its determination of whether an agrarian dispute exists. (Sec. 56, Rep. Act No. 6657)¹ (Limkaichong v. Land Bank of the Philippines)⁶ (Mercado v. Padilla, G.R. No. 228417, 6 October 2025)¹¹