Case Digest (G.R. No. 206992)
Facts:
Land Bank of the Philippines v. Herederos de Ciriaco Chunaco Distileria, Inc., G.R. No. 206992, June 11, 2018, the Supreme Court Third Division, Gesmundo, J., writing for the Court.Herederos de Ciriaco Chunaco Distileria, Inc. (respondent) owned twelve titled parcels totaling 22.587 hectares in Guinobatan, Albay. In November 2001 respondent voluntarily offered the parcels for sale to the Republic under the Comprehensive Agrarian Reform Program (CARP). Land Bank of the Philippines (petitioner), pursuant to its mandate under R.A. No. 6657, prepared a valuation and offered respondent P957,991.30 as compensation; respondent rejected that amount.
Twelve administrative proceedings for preliminary determination of just compensation were conducted before the Provincial Agrarian Reform Adjudicator of Albay (PARAD). In a Decision dated February 17, 2004, the PARAD set just compensation at P195,410.07 per hectare (total P4,455,349.62). Petitioner received that decision on February 24, 2004 and filed a motion for reconsideration on March 9, 2004; the PARAD denied the motion on April 1, 2004 (received April 6, 2004). Petitioner then filed a petition for judicial determination of just compensation before the Regional Trial Court of Legazpi City, Branch 3, acting as Special Agrarian Court (RTC‑SAC), on April 12, 2004 (Civil Case No. 04‑04).
Despite the pending SAC petition, the PARAD declared its February 17, 2004 decision final and executory (Order July 27, 2004) and issued a writ of execution (September 10, 2004). Petitioner filed a petition for certiorari before the Department of Agrarian Reform Adjudication Board (DARAB) on October 12, 2004 seeking to annul the PARAD’s July 27 and September 10 acts; the DARAB denied relief in a Resolution dated July 7, 2005 and denied reconsideration on December 19, 2006. Petitioner invoked certiorari relief from the Court o...(Pro-only)
Issues:
- Whether, after denial of a motion for reconsideration of a PARAD decision, a party is entitled to a fresh fifteen (15)-day reglementary period to commence a petition for judicial determination of just compensation before the Special Agrarian Court (SAC) under R.A. No. 6657...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)