Case Summary (G.R. No. 204526)
Facts of the Case
On December 30, 1996, LBP made an initial valuation of the land amounting to ₱272,347.63. The respondent rejected this valuation, leading to a referral of the dispute to the Provincial Agrarian Reform Adjudicator (PARAD). Following administrative proceedings, the PARAD determined the just compensation to be ₱1,555,084.00 on February 23, 2002. However, this decision was reversed by the Department of Agrarian Reform Adjudication Board (DARAB) on December 10, 2007, reinstating LBP's original valuation.
Procedural History
Upon receiving the DARAB's decision on May 7, 2008, the respondent filed a motion for reconsideration, which was denied on October 18, 2008. Subsequently, on January 5, 2009, Escaro filed a complaint seeking to establish a higher valuation. LBP responded by arguing that the complaint was barred by prior judgment and that the respondent had failed to comply with applicable procedural requirements.
Ruling of the Regional Trial Court
On November 5, 2009, the Regional Trial Court (RTC), sitting as a Special Agrarian Court (SAC), dismissed the respondent’s complaint, citing res judicata. The RTC concluded that the motion for reconsideration did not extend the time to file an original action. Therefore, the DARAB Decision became final and executory.
Ruling of the Court of Appeals
The respondent appealed to the Court of Appeals (CA), which, on June 4, 2012, overturned the RTC's decision. The CA held that the respondent was entitled to proceed with the determination of just compensation, emphasizing the jurisdictional authority of the RTC under Section 57 of RA 6657. The appellate court determined that the procedural actions undertaken by the respondent should not have barred his right to seek judicial review for just compensation.
Issue at Hand
The principal issue revolved around whether the DARAB was automatically divested of its jurisdiction when the respondent filed an original action with the SAC without submitting a Notice of Filing of Original Action (NFOA) and a certified true copy of the petition. LBP contended that the CA misapplied the law regarding the mandatory requirements under the DARAB Rules.
Legal Analysis
In determining the proper legal procedure, the Supreme Court affirmed that the determination of just compensation is a judicial function vested exclusively in the RTCs, not a matter for administrative discretion. It emphasized that any established periods for filing actions must respect the judicial functions outlined under RA 6657, irrespective of DARAB's procedural rules. The Court referenced prior jurisprudence, including Philippine Veterans Bank and Dalauta, which reinforced the principle that the jurisdiction of the RTCs to decide on just compensation was original and exclusive.
Prescription and Timeliness
The Supreme Court addressed the question of whether the respondent's complaint was timely filed. The latently running prescriptive period for claims for just c
...continue readingCase Syllabus (G.R. No. 204526)
Introduction
- The case involves Land Bank of the Philippines (petitioner) seeking to reverse decisions made by the Court of Appeals (CA) regarding just compensation for a parcel of land under the Comprehensive Agrarian Reform Law (RA 6657).
- The CA declared the orders of the Regional Trial Court sitting as a Special Agrarian Court (RTC-SAC) as null and void after finding that the RTC-SAC should have ruled on the merits of the respondent's complaint regarding just compensation.
Factual Antecedents
- Expedito Q. Escaro, represented by Marcelo Q. Escaro, Sr., is an heir of the registered owner of a parcel of agricultural land in Camarines Sur, approximately 24.3990 hectares in size.
- The Department of Agrarian Reform (DAR) placed a significant portion of this land under compulsory acquisition in 1994.
- Land Bank initially valued the property at P272,347.63, which the respondent rejected.
- A Provincial Agrarian Reform Adjudicator (PARAD) later determined just compensation at P1,555,084.00.
- The DARAB reversed this decision in 2007, reinstating the initial valuation.
- Respondent's motion for reconsideration was denied, and subsequently, he filed a complaint with the RTC-SAC seeking a higher valuation.
Ruling of the Regional Trial Court
- The RTC-SAC dismissed the complaint based on the principle of res judicata, asserting that respondent failed to timely file a Notice of Filing of Original Action (NFOA) and had no cause of action due to the finality of the DARAB decision.
- The court emphasized the procedural lapse and stated that th