Case Digest (G.R. No. 199107)
Facts:
Alfonso Singson Cortal, Juanito Singson Cortal, Nenita Codilla, Generoso Pepito Longakit, Ponciana Batoon, and Gregoria Sabroso v. Inaki A. Larrazabal Enterprises, represented by Inaki P. Larrazabal, Jr., the Honorable Regional Director, Regional Office No. VIII, Tacloban City and the Honorable Secretary, Department of Agrarian Reform, G.R. No. 199107, August 30, 2017, Supreme Court Third Division, Leonen, J., writing for the Court.Petitioners (the farmer-beneficiaries) and private respondent Inaki A. Larrazabal Enterprises dispute title to three parcels in Sitio Coob, Barangay Libertad, Ormoc City (Lots 5383‑G, 5383‑N and 5383‑F). In 1988 the lands were compulsorily acquired under Presidential Decree No. 27, emancipation patents and new TCTs were issued to farmer‑beneficiaries including petitioners, and Land Bank records later reflected payments purportedly deposited for Larrazabal Enterprises.
In 1999 Larrazabal Enterprises filed an Action for Recovery with the Office of the Regional Adjudicator, DARAB, contesting cancellation of its TCTs and asserting that just compensation had not been fixed or paid. The Regional Adjudicator (Regional Adjudicator Diloy) in an October 15, 1999 Decision ruled for Larrazabal Enterprises, finding no proof of payment of just compensation and ordering restoration of ownership.
Petitioners appealed to the Department of Agrarian Reform Adjudication Board (DARAB). In a September 16, 2008 Decision the DARAB reversed the regional adjudicator, finding Larrazabal’s cause barred by prescription and laches and giving weight to Land Bank certifications confirming payment. Larrazabal moved for reconsideration; in a September 30, 2009 Resolution the DARAB granted reconsideration and reversed itself, finding deprivation without just compensation and restoring relief to Larrazabal Enterprises.
Petitioners then filed a petition for review under Rule 43 with the Court of Appeals. In its September 30, 2010 Resolution the Court of Appeals dismissed the petition for procedural defects: (1) inconsistency in party‑names (Raymundo Claros Codilla listed in an earlier motion but omitted in the petition and verification); (2) alleged failure of the verification and certification against forum shopping to show competent evidence of identity as required by the Rules on Notarial Practice; (3) failure to attach a copy of the original Complaint filed before the Regional Adjudicator; and (4) counsel’s omission of the place of issue of his Integrated Bar of the Philippines receipt number. A September 7, 2011 Motion for Reconsideration was denied.
Petitioners elevate...(Pro-only)
Issues:
- Was the Court of Appeals justified in dismissing petitioners' Rule 43 appeal for the procedural defects it identified (inconsistent party listing, defective verification/certification of identity, failure to attach the original complaint, and omission of place of issue of coun...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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