Case Digest (G.R. No. 167361)
Facts:
- The case is Land Bank of the Philippines vs. Heirs of Fernando Alsua, G.R. No. 167361, decided on April 2, 2007.
- Respondents include Clotilde S. Alsua, Roberto S. Alsua, Ma. Elena S. Alsua, and Ramon Alsua, heirs of Fernando Alsua.
- Fernando Alsua owned approximately 50 hectares of agricultural land in Catomag, Guinobatan, Albay.
- The Department of Agrarian Reform (DAR) initiated compulsory acquisition under the Comprehensive Agrarian Reform Law.
- Land Bank of the Philippines (LBP) initially valued the land at P2,361,799.91, which was rejected by the respondents.
- The DAR Adjudication Board (DARAB) later set the compensation at P4,806,109.05, which was also opposed by the respondents.
- On April 11, 2002, LBP filed a petition for just compensation in the Regional Trial Court (RTC) of Legazpi City.
- The RTC dismissed the petition on December 4, 2002, due to LBP's failure to prosecute in a reasonable time.
- The dismissal order was delivered to LBP's counsel on December 12, 2002.
- LBP's counsel filed a motion for reconsideration on December 27, 2002, citing excusable negligence, but it was denied as late and lacking merit.
- LBP appealed to the Court of Appeals, which upheld the RTC's dismissal, prompting LBP to petition the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court denied LBP's petition for review on certiorari.
- The Court affirmed the Court of Appeals' Decision dated September 17, 2004, and Resolution dated March 4, 2005.
- It ruled that the service of the dismissal order to the security guard was valid. ...(Unlock)
Ratio:
- The ruling highlighted the necessity of adhering to procedural rules and the finality of court decisions.
- The Court clarified that registered mail must be delivered to the addressee or a person capable of receiving it.
- The security guard was considered capable of receiving the order on behalf of LBP's counsel...continue reading
Case Digest (G.R. No. 167361)
Facts:
The case of Land Bank of the Philippines vs. Heirs of Fernando Alsua, G.R. No. 167361, was decided by the Supreme Court of the Philippines on April 2, 2007. The respondents in this case are Clotilde S. Alsua, Roberto S. Alsua, Ma. Elena S. Alsua, and Ramon Alsua, who are the heirs of the late Fernando Alsua. Fernando Alsua owned approximately 50 hectares of agricultural land located in Catomag, Guinobatan, Albay. The Department of Agrarian Reform (DAR) initiated compulsory acquisition proceedings for these properties under the Comprehensive Agrarian Reform Law. Initially, the Land Bank of the Philippines (LBP) valued the properties at P2,361,799.91, a valuation that the respondents rejected. Following this, the Department of Agrarian Reform Adjudication Board (DARAB) determined the compensation for the lands to be P4,806,109.05, a decision that was also opposed by the respondents. On April 11, 2002, LBP filed a petition for the determination of just compensation in the Regional Trial Court (RTC), Branch 3, Legazpi City. However, the RTC issued an order on December 4, 2002, dismissing the petition due to LBP's failure to prosecute the case within a reasonable time. This order of dismissal was sent via registered mail and was delivered to LBP's counsel on December 12, 2002. Subsequently, LBP's counsel filed a motion for reconsideration on December 27, 2002, citing excusable negligence due to a heavy workload. However, the RTC denied this motion as it was filed one day late and lacked merit. LBP then appealed to the Court of Appeals, which upheld the RTC's dismissal, leading to...