Case Digest (G.R. No. 157903)
Facts:
In the case of Land Bank of the Philippines v. Federico C. Suntay, represented by his assignee, Josefina Lubrica, the respondent Suntay, married to Cristina Aguinaldo-Suntay, was the registered owner of a 3,682.0285-hectare parcel of land located in Sta. Lucia, Sablayan, Occidental Mindoro, evidenced by Transfer Certificate of Title No. T-31 from the Registry of Deeds of Mamburao. In 1972, under the agrarian reform program established by Presidential Decree No. 27, the Department of Agrarian Reform (DAR) expropriated 948.1911 hectares from Suntay's property, primarily consisting of lowland and non-irrigated riceland. The Land Bank and the DAR assessed just compensation for the expropriation at PHP 4,251,141.68, or PHP 4,497.50 per hectare. This valuation was rejected by Suntay, who argued that it constituted a taking of his property without due process and was significantly undervalued.Consequently, Suntay filed a petition with the Office of the Regional Agrarian Reform Adjudi
Case Digest (G.R. No. 157903)
Facts:
Federico C. Suntay, through his assignee Josefina Lubrica, is the registered owner of a large parcel of land in Occidental Mindoro. In 1972, under the government’s land reform program (PD No. 27), the Department of Agrarian Reform (DAR) expropriated a portion of his land. The expropriated lot, largely lowland non-irrigated riceland, was fixed in value at approximately ₱4.5 million by the DAR in conjunction with the Land Bank of the Philippines (petitioner). Disagreeing with this low valuation—which he saw as an unjust taking without due process—Suntay initiated proceedings before the Regional Agrarian Reform Adjudicator (RARAD) to determine just compensation. The RARAD, after summary proceedings, rendered a decision awarding significantly higher compensation of over ₱157 million.Subsequently, the Land Bank filed an action in the Regional Trial Court (RTC), Branch 46, San Jose, Occidental Mindoro, to have the just compensation be fixed at the lower valuation (₱4.25 million). However, the RTC dismissed the petition on the ground that it was filed beyond the 15‑day reglementary period under Section 11, Rule XIII of the DARAB New Rules of Procedure. The petitioner argued that its filing before the RTC was not an appeal from the RARAD’s final decision but rather an original action under its exclusive jurisdiction pursuant to Section 57 of R.A. No. 6657. After a series of motions for reconsideration and a notice of appeal (which was later dismissed by the RTC as well), the petitioner brought a petition for review with the Court of Appeals alleging grave abuse of discretion by the RTC. The Court of Appeals initially granted and issued injunctions but later, on a motion for reconsideration by the respondent, reversed its own decision, dismissing the petition for certiorari. The issue eventually reached the Supreme Court on a petition for review on certiorari.
Issues:
- Whether the RTC erred in dismissing the Land Bank’s petition for the determination of just compensation on technical grounds, treating it as an untimely appeal rather than an original action.
- Whether, under the provisions of R.A. No. 6657—specifically Section 57—the RTC has original and exclusive jurisdiction over petitions for the determination of just compensation, irrespective of the timing issues highlighted by the administrative rules.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)