Case Digest (G.R. No. 221636)
Facts:
Land Bank Philippines v. Court of Appeals and Heirs of Manuel Bolanos, G.R. No. 221636, July 11, 2016, Supreme Court Third Division, Jardeleza, J., writing for the Court.The parcel of land (71.4715 hectares) owned by the private respondents was covered by the Comprehensive Agrarian Reform Program (CARP). Land Bank of the Philippines (LBP), acting under DAR valuation rules, initially valued the property at P1,620,750.72 pursuant to DAR Administrative Order No. 11, s. 1994; the private respondents rejected that valuation but LBP nevertheless deposited the amount in their favor. Farmer-beneficiaries were subsequently awarded certificates of land ownership on March 11, 1996.
On October 29, 1998, the private respondents (the landowners/heirs of Manuel Bolanos) filed before Branch 23, Regional Trial Court (RTC) of Naga City, sitting as a Special Agrarian Court (SAC), a case for determination of just compensation. The SAC ordered a re-valuation; LBP revalued the land under DAR AO No. 5, s. 1998 and arrived at P1,803,904.76. The SAC affirmed that valuation in its Decision dated May 14, 2013.
Private respondents filed a notice of appeal under Rule 41 (ordinary appeal) and the SAC gave the notice due course. The Court of Appeals (CA) required the filing of a brief. LBP moved to dismiss the appeal on the ground that the ordinary appeal was the wrong remedy because appeals from SAC decisions must be by petition for review under Rule 42 pursuant to Section 60 of Republic Act No. 6657. The CA, however, denied LBP’s motion in a Resolution dated May 21, 2015—invoking liberality in construing procedural rules—and denied reconsideration on October 13, 2015.
LBP then filed this petition for certiorari and prohibition with a prayer for a temporary restraining order/preliminary injunction, alleging that the CA committed grave abuse of discretion in allowing the ordinary appeal and thereby excusing the noncompliance with the special ...(Subscriber-Only)
Issues:
- Did the Court of Appeals commit grave abuse of discretion in denying LBP’s motion to dismiss and in accepting an ordinary appeal (Rule 41) from the Special Agrarian Court instead of requiring a petition for review under Rule 42 as mandated by Section 60 of RA No. 6657?
- If the appeal was the wrong mode, did the notice of appeal toll the 15-day period under Section 60 of RA No. 6657 or did the SAC de...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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