Case Digest (G.R. No. 158464)
Facts:
Jocelyn S. Limkaichong v. Land Bank of the Philippines, Department of Agrarian Reform, G.R. No. 158464, August 02, 2016, the Supreme Court En Banc, Bersamin, J., writing for the Court.Petitioner Jocelyn S. Limkaichong was the registered owner of four agricultural parcels (totaling 19.6843 hectares) in Villegas, Guihulngan, Negros Oriental, covered by four Original Certificates of Title. In 1998 the Department of Agrarian Reform Adjudication Board (DARAB) issued Notices of Land Valuation and Acquisition valuing the parcels (values ranged from P140,611.65 to P177,074.93). Petitioner rejected the DARAB valuation; DARAB thereupon conducted summary administrative proceedings and, on May 28, 1999, issued an order affirming its valuation.
On August 19, 1999 petitioner filed with the Regional Trial Court (RTC), Dumaguete City, a complaint docketed as Civil Case No. 12558 against Land Bank of the Philippines (LBP) and the Department of Agrarian Reform (DAR) for judicial determination of just compensation (asking the RTC to set aside the DARAB valuation and fix fair market value). Respondents answered and moved to dismiss, invoking Section 51 of R.A. No. 6657 and submitting a June 23, 2000 DARAB clerk’s certification that the May 28, 1999 order had become final for lack of a timely appeal.
The RTC, sitting as a Special Agrarian Court (SAC), granted the motion to dismiss on June 7, 2001, holding the complaint was filed beyond the 15-day reglementary period prescribed in the DARAB rules and thus the DARAB valuation had become final; the trial court relied on the then-prevailing jurisprudence in Philippine Veterans Bank v. Court of Appeals. Petitioner’s motion for reconsideration was denied. She filed a petition for certiorari in the Court of Appeals (CA) on October 22, 2001; the CA, on November 22, 2002, dismissed the certiorari petition as th...(Pro-only)
Issues:
- Was a petition for certiorari a proper remedy to assail the RTC’s dismissal of Civil Case No. 12558?
- Was the RTC’s dismissal — for petitioner’s alleged failure to file within the 15-day period so that the DARAB valuation became final — fair and proper under R.A. No. 6657 and contr...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)