G.R. No. 188376 - Land Bank of the Philippines vs. Suntay

Respondent Federico Suntay owned extensive agricultural land in Sta. Lucia, Sablayan, Occidental Mindoro.
In 1972, pursuant to Presidential Decree No. 27, the Department of Agrarian Reform (DAR) expropriated a portion (948.1911 hectares) of Suntay’s land.
The matter concerned the determination of “just compensation” due to the expropriation under Republic Act No. 6657 (the Comprehensive Agrarian Reform Law or CARL).

The DAR, in coordination with petitioner Land Bank of the Philippines and DAR officials, initially fixed the compensation value at ₱4,497.50 per hectare, amounting to ₱4,251,141.68.
Dissatisfied with the valuation, Suntay filed a petition for the determination of just compensation before the Office of the Regional Agrarian Reform Adjudicator (RARAD) in Region IV, DARAB Case No. V-0405-0001-00.
On January 24, 2001, after summary proceedings, RARAD Conchita MiAas rendered a decision fixing the total just compensation at ₱157,541,951.30.
Land Bank moved for reconsideration but was denied by RARAD MiAas shortly thereafter.

On April 20, 2001, Land Bank instituted a separate petition for the judicial determination of just compensation in the Regional Trial Court (RTC) acting as a Special Agrarian Court in San Jose, Occidental Mindoro (Agrarian Case No. R-1241).
The petition sought to fix the compensation at the originally agreed valuation of ₱4,251,141.67, asserting that the RTC has original and exclusive jurisdiction over such determinations.
Suntay, through various motions, contended that the judicial remedy was barred by the lapse of the regulatory period prescribed in the DARAB rules.

Despite the pendency of the RTC case, RARAD MiAas declared her January 24, 2001 decision final and executory, issuing a writ of execution in DARAB Case No. V-0405-0001-00.
Land Bank challenged this finality through motions and petitions before the Court of Appeals (CA) in a special civil action for certiorari (CA-G.R. SP No. 70015) and also through a petition for certiorari in DARAB matters (CA-G.R. SP No. 66710).
The CA initially granted certiorari in Land Bank’s favor by nullifying the RTC’s orders dismissing its appeal on technical grounds but later reversed itself on reconsideration, dismissing Land Bank’s petition and thereby upholding the finality of the RARAD decision.

On May 6, 2003, Land Bank appealed to the Supreme Court in G.R. No. 157903, challenging the RTC’s dismissal and arguing that its petition was not an appeal from an administrative decision but an original action.
On October 11, 2007, the Supreme Court rendered a decision in Land Bank v. Suntay (G.R. No. 157903), holding that the RTC possessed exclusive original jurisdiction over petitions for just compensation and that the treatment of the petition as an appeal was erroneous.
Notwithstanding the ruling, further execution proceedings were undertaken. RARAD MiAas, again, ordered the resumption of execution by directing sheriffs to enforce the writ issued earlier.
The DARAB sheriffs proceeded with various acts of execution, including notices of levy and the public auction of Land Bank’s levied assets (shares of PLDT, MERALCO, and bonds).

On October 30, 2008, RARAD MiAas directed the DARAB sheriffs to resume the execution of the alias writ of execution even though earlier actions and the Supreme Court’s TRO order (October 24, 2005) had maintained the status quo ante.
Subsequent orders by RARAD Casabar (December 15, 2008 and December 17, 2008) sought to recall or cancel previous execution measures, including quashing the public auction and canceling the transfer of stock certificates in favor of Josefina Lubrica, the assignee of Suntay.
Land Bank, asserting its rights and disputing the execution methods, filed several motions—including petitions for certiorari and urgent motions for a TRO—to stop the execution of the contested orders, particularly the levy against its MERALCO shares.
Throughout the period, procedural complications arose regarding the proper timing for filing appeals and the effect of finality of RARAD decisions invoked from both DARAB v. Lubrica (G.R. No. 159145) and Land Bank v. Suntay (G.R. No. 157903).

The case underwent multiple procedural stages that included: petitions for review on certiorari, motions for reconsideration, and competing claims on the proper issue resolution.
The conflicting rulings from administrative adjudicators and the RTC, as well as subsequent CA decisions, created legal uncertainty, particularly on issues of jurisdiction, finality of decisions, and the legality of the execution process.
Eventually, the Supreme Court granted the petition for review on certiorari in G.R. No. 188376, reversing the CA’s decision and clarifying the jurisdictional and execution issues, while ordering the RTC to resume proceedings on the determination of just compensation.

Whether the RTC, acting as a Special Agrarian Court, has original and exclusive jurisdiction to determine just compensation under CARL.
Whether the petition filed by Land Bank for judicial determination is an original action or merely an appeal from the administrative decision of RARAD MiAas.

Whether the decision of RARAD MiAas (and its subsequent declarations of finality) attained finality and executory effect, particularly in light of the procedural challenges by Land Bank.
The applicability and binding effect of the rulings in DARAB v. Lubrica (G.R. No. 159145) versus Land Bank v. Suntay (G.R. No. 157903).

Whether the subsequent orders by RARAD Casabar (December 15, 2008 and December 17, 2008) rendered Land Bank’s petition for certiorari moot and academic.
Whether these recalled orders effectively nullified the earlier execution directive issued by RARAD MiAas on October 30, 2008.

Whether the issuance and enforcement of the writs of execution (including the alias writ of execution) by RARAD MiAas and the DARAB sheriffs complied with the law and the DARAB Rules of Procedure.
Whether the subsequent levy and public auction of Land Bank’s shares (including MERALCO shares) were valid given the segregation of Land Bank’s proprietary funds from the Agrarian Reform Fund.

Whether Land Bank is entitled to the dividends and other benefits accruing from the levied and auctioned MERALCO shares as if the execution measures had never taken effect.
Whether the actions taken by the DARAB sheriffs violated Land Bank’s rights under the mandates governing the ARF and its proprietary functions.