**Facts**: The Roman Catholic Bishop of Malolos, Inc. (RCBMI) sought to recover portions of a parcel of land awarded to Mariano Marcos under the “Tenants Emancipation Decree”, Presidential Decree No. 27, enacted on October 21, 1972. RCBMI argued that these lots were not used for rice production, which was the decree’s focus, but instead for social and humanitarian programs. Consequently, they obtained an order in 1982 from the Ministry of Agrarian Reform (MAR) cancelling one of the Certificates of Land Transfer (CLT) awarded to Marcos, a decision that became final due to Marcos’s delayed appeal. Despite this, Marcos’s heirs refused to vacate, leading to RCBMI filing a complaint in 1994 before the Provincial Agrarian Reform Adjudicator (PARAD) which ruled in favor of RCBMI in 1995.
The decision was affirmed by the Department of Agrarian Reform Adjudication Board (DARAB) in 2001 and became final in 2004. Challenges to the execution of the final decision ensued, culminating in the issuance of a writ of execution in 2010 by PARAD, which was initially suspended and then re-instated in 2012 following deliberations on whether the land was under Comprehensive Agrarian Reform Law coverage.
Further attempts by the Heirs of Marcos to thwart the execution, including a motion to quash the writ based on technical grounds were presented. RCBMI contended with these delays by seeking a resolution from the Court of Appeals (CA), which dismissed their petition on the ground of non-exhaustion of administrative remedies. This led to the present petition for review on certiorari before the Supreme Court.
**Issues**:
1. Whether the Court of Appeals erred in dismissing RCBMI’s petition for certiorari and mandamus under Rule 65 for non-exhaustion of administrative remedies.
2. Whether the Provincial Agrarian Reform Adjudicator acted in excess of its jurisdiction in granting the Heirs of Marcos’ Motion to Quash the Writ of Execution.
**Court’s Decision**:
The Supreme Court granted the petition, reversing the Resolutions of the Court of Appeals and reinstating the PARAD’s Order that granted RCBMI’s Motion for the Issuance of a Writ of Execution. The Supreme Court found that the CA erred in applying the principle of exhaustion of administrative remedies as exceptions to the principle applied in this case, notably the unreasonable delay that would prejudice RCBMI. Further, the Court held that the PARAD’s delay in issuing the writ of execution and its subsequent decision to quash the writ were not in accordance with the procedural rules, which ultimately prejudiced RCBMI.
**Doctrine**:
The Supreme Court reiterated the doctrine of non-exhaustion of administrative remedies and its exceptions, notably when there is an unreasonable delay or official inaction that will irretrievably prejudice the complainant. The Court emphasized the principle of finality and immutability of decisions, underscoring that decisions which have become final and executory are to be executed as a matter of right and without delay.
**Class Notes**:
– **Non-exhaustion of Administrative Remedies**: A principle that requires all administrative remedies to be exhausted before resorting to judicial intervention, subject to exceptions such as unreasonable delay, among others.
– **Doctrine of Finality of Decision**: Once a decision becomes final and executory, it is immutable and unalterable and must be executed as a matter of right.
– **Rule 65, 1997 Rules of Court**: This rule provides for the remedies of certiorari, prohibition, and mandamus against lower courts or bodies in cases of lack or excess of jurisdiction or grave abuse of discretion.
– **1989 DARAB Rules of Procedure**: Govern the procedural aspects in cases involving agrarian disputes, emphasizing a just, speedy, and inexpensive adjudication and settlement.
**Historical Background**:
This case reflects the complex interplay between land ownership, agrarian reform, and judicial processes in the Philippines. It highlights the challenges faced in enforcing agrarian reform laws, the procedural intricacies involved in the execution of final and executory decisions, and the potential for delay and obstruction in the judicial process.
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