G.R. No. 204526 - Land Bank of the Philippines vs. Escaro

Petitioner: Land Bank of the Philippines (LBP), responsible for the initial valuation of the land and the subsequent administrative proceedings.
Respondent: Expedito Q. Escaro (in some records referred to as Agapito Escaro), represented by Marcelo Q. Escaro, Sr., an heir to the registered owner of a parcel of land.
Property: A parcel of land in Sibao, Calabanga, Camarines Sur, covering approximately 24.3990 hectares.

On August 30, 1994, the Department of Agrarian Reform (DAR) placed 24.0467 hectares of the parcel under a compulsory acquisition scheme pursuant to Republic Act No. 6657 (the Comprehensive Agrarian Reform Law, RA 6657).
LBP, pursuant to its mandate under RA 6657, made an initial valuation of the property at approximately P272,347.63, as stated in a Notice of Valuation and Acquisition dated December 30, 1996.
Respondent rejected the petitioner’s valuation, leading to further proceedings.

The matter was referred to the Provincial Agrarian Reform Adjudicator (PARAD) of Camarines Sur around 1996.

The PARAD conducted summary administrative proceedings for a preliminary determination of just compensation.
On February 23, 2002, the PARAD rendered a decision fixing the just compensation at P1,555,084.00.

Petitioner elevated the dispute to the Department of Agrarian Reform Adjudication Board (DARAB).

On December 10, 2007, the DARAB reversed the PARAD’s determination and reinstated petitioner’s valuation at approximately P272,347.70.
Respondent moved for reconsideration of the DARAB decision on May 20, 2008; however, the motion was denied in an Order dated October 18, 2008.

On January 5, 2009, respondent filed a complaint with the Regional Trial Court (RTC) sitting as a Special Agrarian Court (SAC) seeking a determination that the proper valuation of the land be fixed at P1,681,199.00 (approximately P70,000.00 per hectare).
In its answer, LBP raised multiple defenses, notably:

Alleging respondent’s failure to file a Notice of Filing of Original Action (NFOA) as mandated by the DARAB Rules.
Arguing that respondent did not have a valid cause of action because the issue was already barred by prior judgment.

On November 5, 2009, the RTC-SAC dismissed the complaint for determination of just compensation on the ground of res judicata, emphasizing respondent’s procedural lapses (including the failure to file the NFOA and failure to submit a certified true copy of the complaint to the DARAB).
A subsequent motion for reconsideration of the dismissal was denied in an Order dated January 4, 2010.

Respondent filed a petition for review under Rule 42 of the Rules of Court against the RTC-SAC ruling.
The CA, on June 4, 2012, granted the petition for review, set aside the previous RTC-SAC dismissal orders, and remanded the case back for further proceedings.
The CA’s decision underscored that the RTC-SAC has original and exclusive jurisdiction over petitions for determination of just compensation under Section 57 of RA 6657.

The filing of a motion for reconsideration with the DARAB did not toll the 15-day period prescribed for filing an original action with the RTC-SAC.
The failure to file the mandatory NFOA and submit the certified copy of the complaint rendered the DARAB Decision final and executory.
These procedural lapses barred respondent’s complaint due to res judicata as the valuation order had attained finality.

The petition for review on certiorari was ultimately filed by LBP for the reversal of the CA’s June 4, 2012 Decision and related orders.
The Supreme Court reviewed the administrative and judicial proceedings, including the alleged procedural lapses and the issue of jurisdiction and timeliness in filing the complaint for just compensation.

Whether the filing of a motion for reconsideration with the DARAB tolls or affects the 15-day prescription period for filing an original action for determination of just compensation with the RTC-SAC.
Whether the failure to comply with the requirement to file a Notice of Filing of Original Action (NFOA) along with a certified true copy of the petition renders the DARAB decision final and executory.
Whether respondent’s complaint for determination of just compensation is barred by res judicata as a result of the alleged procedural lapses and the finality of the DARAB decision.
The proper computation of the prescriptive period for filing an action for determination of just compensation, including the contention between the 15-day period prescribed by the DARAB Rules and the 10-year period provided under Article 1144(2) of the Civil Code.