G.R. No. 190660 - Land Bank of the Philippines vs. Court of Appeals

Case Summary (G.R. No. 190660)

Factual Background

Private respondent Elizabeth P. Diaz owned a parcel of agricultural land of approximately fifteen hectares in San Ricardo, Talavera, Nueva Ecija covered by Transfer Certificate of Title No. 197132. Ten hectares were expropriated by the Department of Agrarian Reform under Presidential Decree No. 27 and Executive Order No. 228. The DAR valued the expropriated land at P54,880.59 plus increment of P143,041.59 for a total of P197,922.18. Dissatisfied, Elizabeth, through her attorney-in-fact Francisca P. De Guzman, filed a complaint for the fixing of just compensation.

Trial Court Proceedings

The complaint was docketed as Special Agrarian Case No. 1194-G before the Regional Trial Court of Guimba, Nueva Ecija, Branch 33, sitting as a Special Agrarian Court (SAC). Three Commissioners were appointed to determine just compensation. By Decision dated June 21, 2006, the SAC adopted the DAR valuation based on average gross production and fixed just compensation plus increment at P19,107.235 per hectare or a total of P197,922.29. The SAC ruled that, under the formula used in Gabatin v. LBP, the Commissioners' Report and the fair market or assessed value could not be considered in valuation. A motion for reconsideration was denied by Order dated August 31, 2006.

Court of Appeals Proceedings

Elizabeth elevated the case to the Court of Appeals by ordinary appeal. Land Bank and the DAR did not file appellees' briefs as directed. During the appeal, Land Bank filed a Motion for Leave to Admit Defendant-Appellee[’s] Motion to Dismiss Appeal, contending that the ordinary appeal was the wrong remedy and that the proper remedy was a petition for review under Section 60 of RA 6657, thereby asserting that the SAC decision had become final under Land Bank of the Philippines v. De Leon when no proper remedy was filed within the reglementary period. The Court of Appeals denied the motion to dismiss by Resolution dated June 2, 2009, faulting Land Bank for failing to file an appellee's brief and for the lateness of its motion to dismiss.

Petitioner's Contentions

In the petition for certiorari to the Supreme Court, Land Bank maintained that the SAC Decision had become final and executory because the proper mode of appeal was by petition for review under Section 60, RA 6657, and that Elizabeth’s ordinary appeal did not arrest finality. Land Bank further alleged bad faith on Elizabeth’s part in serving her motions at the Land Bank main office in Manila rather than to counsel of record at the Land Bank Field Office in Cabanatuan City.

Supreme Court's Analysis

The Court found the petition meritorious. It observed that under Land Bank of the Philippines v. De Leon the correct mode of appeal from decisions of Regional Trial Courts sitting as Special Agrarian Courts is by petition for review under Rule 42 of the Rules of Court and not by an ordinary appeal under Rule 41. The Court explained that Section 60 of RA 6657 clearly designates the petition for review as the proper mode of appeal in agrarian cases and that there is no true conflict between Sections 60 and 61 because the Rules of Court do not prescribe ordinary appeals as the appropriate mode for SAC decisions.

Legal Reasoning

The Court reasoned that Section 61’s general reference to the Rules of Court does not negate the express prescription of Section 60 and can be harmonized by a suppletory application of pertinent provisions of the Rules of Court, specifically Rule 42 for petitions for review. The omission of Special Agrarian Courts from Section 1 of Rule 43 did not preclude the use of a petition for review because Rule 43 addresses quasi‑judicial agencies and the Court of Tax Appeals and is not a proper classification for Regional Trial Courts acting as Special Agrarian Courts. The Court emphasized the policy objective behind adopting the petition for review in agrarian eminent domain cases: the need for absolute dispatch in fixing just compensation so that landowners receive fair recompense within a reasonable time and are not left waiting for protracted periods. The Court reiterated the settled principle that appeal is a statutory privilege, not a natural right, and that failure to perfect the remedy in the manner and within the period prescribed by law is jurisdictional and renders the judgment final and executory.

Ruling and Disposition

The Supreme Court granted the petition. It set aside the Co

Case Syllabus (G.R. No. 190660)

Parties and Procedural Posture

Land Bank of the Philippines was the petitioner in a petition for review on certiorari seeking to set aside a Resolution of the Court of Appeals dated June 2, 2009.
Elizabeth P. Diaz, represented by Francisca P. De Guzman as attorney-in-fact, was the private respondent and registered owner of the expropriated land in question.
The case originated as Special Agrarian Case No. 1194-G before the Regional Trial Court of Guimba, Nueva Ecija, Branch 33 acting as a Special Agrarian Court (SAC).
The Supreme Court adjudicated the petition and resolved the question whether the appeal filed by Elizabeth was the proper mode to challenge the SAC decision.

Key Factual Allegations

Elizabeth was the registered owner of approximately fifteen hectares of agricultural land in San Ricardo, Talavera, Nueva Ecija covered by TCT No. 197132.
The Department of Agrarian Reform expropriated ten hectares of the land under Presidential Decree No. 27 and Executive Order No. 228.
The DAR valued the expropriated land at P54,880.59 plus an increment of P143,041.59, amounting to P197,922.18 in total.
Elizabeth, through her attorney-in-fact, filed a complaint on November 28, 2001, praying that just compensation be fixed at P350,000 per hectare or a total of P5,250.000.
Three Commissioners were appointed to determine just compensation and the SAC, by Decision dated June 21, 2006, adopted the DAR valuation and fixed just compensation plus increment at P19,107.235 per hectare or a total of P197,922.29.

Procedural History

The SAC denied Elizabeth's motion for reconsideration by Order dated August 31, 2006.
Elizabeth filed an appeal to the Court of Appeals by ordinary appeal under Rule 41 of the Rules of Court.
Land Bank and the DAR failed to file appellees' briefs as directed by the appellate court.
Land Bank filed a Motion for Leave to Admit Defendant-Appellee's Motion to Dismiss Appeal, asserting the appeal was the wrong remedy and should have been by petition for review under Section 60 of RA 6657.
The Court of Appeals denied Land Bank's motion to dismiss by Resolution dated June 2, 2009, citing Land Bank's failure to file an appellee's brief and the tardiness of its motion.
Land Bank filed the present petition for review on certiorari in the Supreme Court, and the Court of Appeals held action in abeyance per Resolution dated June 7, 2010.

Issues Presented

Whether an ordinary appeal under Rule 41 was the proper mode of appeal from the SAC Decision in a just compensation agrarian case.
Whether the SAC Decision had become final and executory by reason of the alleged failure of the proper party to file the correct remedy within the reglementary period.
Whether the Court of Appeals acquired jurisdiction over the appeal filed by Elizabeth in view of the claimed finality of the SAC Decision.

Contentions of the Parties

Land Bank of the Philippines contended that the proper mode of appeal was a petition for review under Rule 42 in accordance with Section 60 of RA 6657, and that the SAC Decision had thus become final and executory rendering the appellate court without jurisdiction.
Land Bank further alleged bad faith on the part of Elizabeth in transmi