Title
Land Bank of the Philippines vs. De Leon
Case
G.R. No. 143275
Decision Date
Mar 20, 2003
Landowners sought compensation for expropriated land; LBP appealed via wrong mode. SC upheld petition for review as proper appeal method but applied ruling prospectively to avoid dismissing pending cases.
petition for review
mode of appeal
prospective application
A

Case Digest (G.R. No. 143275)

Facts:

  • Parties and procedural posture
    • Land Bank of the Philippines (LBP) filed a motion for reconsideration dated October 16, 2002 and a supplement dated November 11, 2002, seeking the reversal of the Court’s Decision dated September 10, 2002 that denied LBP’s petition for review.
    • Respondents were the spouses Arlene and Bernardo de Leon.
  • Agrarian case in the Regional Trial Court acting as a Special Agrarian Court
    • The respondents filed a petition to fix the just compensation of a parcel of land before the Regional Trial Court of Tarlac, Branch 63, acting as a Special Agrarian Court.
    • On December 19, 1997, the agrarian court rendered summary judgment fixing just compensation:
1) PHP 1,260,000 for 16.69 hectares of riceland; and 2) PHP 2,957,250 for 30.4160 hectares of sugarland.
  • Appeals taken and how each was docketed in the Court of Appeals
    • The Department of Agrarian Reform (DAR) and LBP both filed separate appeals using different modes.
    • DAR filed a petition for review, which was assigned to the Special Third Division of the Court of Appeals and docketed as CA-G.R. SP No. 47005.
    • LBP filed an ordinary appeal by filing a notice of appeal, which was assigned to the Fourth Division of the Court of Appeals and docketed as CA-G.R. CV No. 60365.
    • The appellate courts, in the DAR petition for review, partially reconsidered the trial court’s decision and recomputed compensation based on a specified selling price, and ordered legal interest from a specified period until full payment by the government.
  • Rulings of the Court of Appeals
    • On November 6, 1998, the Court of Appeals Special Third Division rendered a decision in DAR’s petition for review.
1) The petition for review was given due course. 2) The decision dated February 9, 1998 was partially reconsidered. 3) The trial court was ordered to recompute compensation based on the selling price of palay at 213.00 per cavan. 4) Legal interest of 6% on the compensation fixed was imposed from 1990 until full payment by the government.
  • On February 15, 2000, the Court of Appeals Fourth Division dismissed LBP’s ordinary appeal.
1) The primary ground was that LBP availed of the wrong mode of appeal.
  • Review by the Supreme Court and denial of LBP’s petition
    • LBP filed a motion for reconsideration in the Court of Appeals, but it was denied.
    • On July 14, 2000, LBP filed in the Supreme Court a petition for review of the Court of Appeals decision.
    • On September 10, 2002, the Supreme Court rendered a Decision affirming the Court of Appeals resolutions, with the dispositive portion:
1) The appealed resolutions dated February 15, 2000 and May 22, 2000 were affirmed. 2) No costs.
  • Supreme Court’s reasoning in the September 10, 2002 Decision
    • The Court held that Section 60 of RA 6657 is clear in providing petition for review as the appropriate mode of appeal from decisions of Special Agrarian Courts.
    • The Court held that Section 61 of RA 6657, which LBP invoked for ordinary appeal, is only a general reference to the Rules of Court and does not categorically prescribe ordinary appeal as the correct mode.
    • The Court interpreted Section 61 as meaning that the specific rules for petitions for review in the Rules of Court and other relevant procedures of appeals shall be followed in appealed decisions of Special Agrarian Courts.
    • The Court also held that Section 60 of RA 6657 is constitutional and does not violate the Court’s rule-making power under the protection and enforcement of constitutional rights, pleadings, practice and procedure in all courts, admission to the practice of law, the Integrated Bar, and legal assistance to the underprivileged.
    • The Court ruled that the Rules of Court does not categorically prescribe ordinary appeal as the exclusive mode of appeal from decisions of Special Agrarian Courts.
    • The Court concluded that the reference in Section 61 to the Rules of Court even supports petition for review as the appropriate way to appeal decisions of the Special Agrarian Courts.
    • The Court reasoned that under Section 5(5), Article VIII of the 1987 Constitution, rules of procedure of special courts and quasi-judicial bodies remain effective unless disapproved by the Supreme Court, and that because Section 60 is a special procedure and the Court had not provided a particular process for appeals from agrarian courts, Section 60 did not encroach on the Court’s rule-making power.
  • LBP’s motion for reconsideration and supplement
    • LBP reiterated that Section 60 of RA 6657 is unconstitutional.
    • LBP argued that a legislative act like Section 60 infringes the Court’s exclusive rule-making power under the 1987 Constitution.
    • In the alternative, LBP requested prospective application of the September 10, 2002 ruling.
    • LBP asserted that more than 60 similar agrarian cases filed by LBP via ordinary appeal before the Court of Appeals were at risk of dismissal on technical grounds.
    • LBP argued that such dismissals would create financial havoc to:
1) LBP as financial intermediary of the Comprehensive Agrarian Reform Program; and 2) the national treasury, given the already depressed economic condition.
  • In the interest of fair play, equity, and justice, LBP stressed the need for relaxation of the rules to give substantial consideration to the appealed cases.
  • The supplement added figures and fiscal consequences, including reference to:
1) the initial CARP fund of PHP 595.8 Million in 1987 and total CARP funds released to LBP, paid to landowners, and utilized for operational support amounting to PHP 29.863 Billion as of September 2002; 2) a statutory budget of PHP 100 Billion for the CARP; 3) the national treasury lacking money to pay landowners’ claims if cases were dismissed due to wrong mode of appeal; 4) a fiscal deficit of PHP 180 Billion for the current year; 5) LBP’s landowners compensation funding requirement for 2002 of PHP 5.690 Billion, contrasted with a Congress-approved budget under the General Appropriations Act of 2002 of PHP 2.854 Billion, leaving a funding gap of PHP 2.836 Billion; 6) total cash advances for landowners compensation as of September 2002 of PHP 3.044 Billion; 7) projected cash advances by end of December 2002 increasing by PHP 900 Million for a projected advance of PHP 3.944 Billion for 2002; 8) a Special Allotment Release Order (SARO) still unfunded for PHP 2.189 Billion; and 9) projected net unrefunded advance by end of December 2002 of PHP 1.755 Billion.
  • The Court’s disposition of the motion and clarification of the ruling’s effect
    • The Court found it needless to re-discuss the September 10, 2002 reasons explaining why Section 60 of RA 6657 did not encroach on the constitutional rule-making power.
    • The Court clarified application and effect on LBP’s pending cases that were filed as ordinary appeals before the Court of Appeals.
    • The Court treated the issue as novel at the time, and it emphasized that the Decision would operate as a landmark ruling on the proper way to appeal decisions of Special Agrarian Courts.
      • ...(Subscriber-Only)

Issues:

  • Constitutionality of Section 60 of RA 6657
    • Whether Section 60 of RA 6657 is unconstitutional for allegedly infringing the Court’s exclusive rule-making power under the 1987 Constitution.
  • Proper mode of appeal from decisions of Special Agrarian Courts
    • W
    ...(Subscriber-Only)
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