G.R. No. 187801 - Heirs of Banaag vs. AMS Farming Corp.

Petitioners: Heirs of Leonardo Banaag (including Marta R. Banaag, Teresita B. Mendoza, Honorato Banaag, Imelda Banaag, Diosdado Banaag, Preciosa Posadas, and Antonio Banaag; additionally, spouses Pedro Mendoza and Teresita Mendoza)
Respondents: AMS Farming Corporation and Land Bank of the Philippines
Subject: Dispute over the rightful ownership and valuation of standing crops and improvements on several parcels of agricultural land located at Sampao, Kapalong, Davao Del Norte

The petitioners are owners and/or heirs of agricultural lands with several Transfer Certificates of Title (e.g., T-9891, T-7778, T-7775, T-7894, T-7776) covering varying hectares.
The lands were historically developed under a long-term lease arrangement.

From 1970 to 1995, the lands were leased to AMS Farming Corporation, which developed Cavendish banana plantations and made necessary improvements and infrastructures.
After the original lease expired, a Memorandum of Agreement (MOA) was allegedly executed, extending the lease term until September 30, 2002.
In 1999 the lands were placed under the coverage of the Compulsory Acquisition Scheme of the Comprehensive Agrarian Reform Program (CARP).

The Land Bank of the Philippines computed the valuation of the raw lands as part of the CARP process.
The petitioners rejected this valuation, prompting summary administrative proceedings before the Regional Agrarian Reform Adjudicator (RARAD).

On July 31, 2000, the RARAD rendered a Decision adopting the LBP’s valuation for the raw lands.
Subsequently, AMS filed an Urgent Motion to Value the Standing Crops and Improvements, which led RARAD to direct the LBP to value these at over P32 million.
The RARAD issued a Consolidated Decision on December 11, 2006, awarding just compensation for the raw lands to the petitioners and for the standing crops and improvements to AMS.

Petitioners and LBP’s appeal to the Department of Agrarian Reform Adjudication Board (DARAB) Central Office was denied for being an improper remedy, and a writ of execution was issued to enforce the RARAD Consolidated Decision.
LBP later sought an injunction to restrain enforcement of the decision while elevating its appeal.

Petitioners separately filed a claim (February 16, 2005) asserting ownership of the standing crops and improvements on the ground that the lease contract with AMS had expired in 1995.
They argued that AMS’s so-called MOA was not valid or agreed to by them, and that failure by AMS to remove the improvements (as stipulated in the lease) rendered such assets theirs.

In Civil Case No. 3867 filed on June 22, 2007 before the Regional Trial Court (RTC) of Tagum City, petitioners sought a determination of ownership over the crops and improvements.
AMS moved for dismissal on several grounds, including that of forum‑shopping, arguing that similar issues were pending and had been resolved in proceedings before the DARAB.
The RTC issued an Order on July 7, 2008, dismissing the complaint for forum‑shopping, and a subsequent Order on March 23, 2009 denied petitioners’ motion for reconsideration.

Whether the petition, filed under Rule 45 of the Rules of Court, should be dismissed for lack of specification of the applicable rule.
Whether the petition’s belated filing beyond the extended deadline should automatically warrant its dismissal.

Whether the dispute over the ownership of the standing crops and improvements falls within the jurisdiction of the DARAB or, alternatively, the RTC (sitting as a Special Agrarian Court).
Whether the DARAB’s Consolidated Decisions on valuation can be considered res judicata in a civil suit for the determination of ownership.

Whether AMS, as lessee, is entitled to claim just compensation for the standing crops and improvements under the Comprehensive Agrarian Reform Law (CARL) or should seek remedy under the Civil Code provisions on lease contracts.
Whether the petitioners’ assertion of ownership of the crops and improvements—predicated on the expiration of the lease—precludes or overrides the earlier decisions awarding these to AMS.

Whether the issue presented is one of law capable of resolution without a detailed reexamination of evidentiary matters.
How the decisions rendered in similar cases (e.g., Land Bank of the Philippines v. AMS Farming Corporation) influence the interpretation of rights under the CARL and Civil Code.