G.R. No. 167886 - Land Bank of the Philippines vs. Pamintuan Development Company

The case involves Land Bank of the Philippines (LANDBANK) challenging the denial of its notice of appeal in an agrarian reform dispute.
The dispute centers on DARAB Case No. 1204-0545-2003 for the “Preliminary Determination of Just Compensation” on respondent Pamintuan Development Company’s 274.9037-hectare lot in San Vicente, Makilala, Cotabato.
DARAB rendered a decision on April 27, 2004, fixing the just compensation at ₱58,237,301.68 and subsequently denied a motion for reconsideration by LANDBANK.

LANDBANK was initially represented by Piczon, Beramo & Associates at trial.
On June 4, 2004, Attys. Engilberto F. Montarde and Felix F. Mesa filed a Notice of Entry of Appearance on behalf of LANDBANK.
Within the prescribed period, on June 15, 2004, these counsels also filed a Notice of Appeal via registered mail, accompanied by a Certification signed by Loreto B. Corotan, Head of LANDBANK’s Agrarian Operations Center.
Respondent argued that the new counsels lacked proper authorization, questioning whether LANDBANK had effected a valid substitution of its former counsel.

On August 2, 2004, DARAB issued an order holding that Attys. Montarde and Mesa were without authority to represent LANDBANK since there was no valid substitution of the prior counsel.
The order declared that the April 27, 2004 decision had become final and executory based on the allegedly invalid notice of appeal.
LANDBANK filed a motion for reconsideration supported by two memoranda confirming the authority of Atty. Montarde to file the appeal.
The DARAB denied the motion for reconsideration, and the Court of Appeals later dismissed LANDBANK’s petition, sustaining DARAB’s finding regarding the counsel’s authority.

LANDBANK filed the petition for certiorari, challenging both the decision of DARAB and the Court of Appeals.
A temporary restraining order was issued on June 6, 2005, enjoining the execution of DARAB’s April 27, 2004 decision.
The central factual dispute surrounding the authority of the new counsel to represent LANDBANK remained unresolved at lower levels.

Whether the appearance of Attys. Montarde and Mesa via their Notice of Entry and subsequent Notice of Appeal was legally sufficient to bind LANDBANK.

Does the filing of a Notice of Entry of Appearance create a presumption that the counsel is properly authorized?
Is a Special Power of Attorney (SPA) and accompanying memoranda adequate to establish the authority for filing the notice of appeal?

Whether the failure to file a formal substitution of counsel invalidates the actions taken by the new counsel on behalf of LANDBANK.

Can the mere appearance of additional counsel be interpreted as a collaboration rather than a substitution?
Should the absence of a formal notice of substitution affect the validity of the appeals process?

Whether the rigid application of procedural rules regarding substitution and appearance frustrates the just, speedy, and inexpensive determination of the dispute.