Case Summary (G.R. No. 166309-10)
Case Background and Proceedings
The LBP evaluated the land at P5,871,689.03 for acquisition. After the respondent rejected this amount, the Department of Agrarian Reform (DAR) conducted summary proceedings to determine just compensation. Subsequent to these proceedings, on October 14, 1998, the Provincial Agrarian Reform Adjudicator (PARAD) fixed the just compensation at P10,956,963.25. However, the petitioner LBP contested this amount and filed a petition before the Regional Trial Court (RTC) of Sorsogon for judicial determination of just compensation almost a year later, on September 6, 1999, substantially beyond the prescribed 15-day period following the PARAD's decision.
Respondent's Motions and Dismissals
The respondent filed a motion to dismiss, arguing that LBP's acceptance of the DAR's valuation formed a binding contract, equating to res judicata. This motion was granted by the RTC on October 25, 2000, leading to the dismissal of LBP's petition due to it being filed late. LBP contended that the delay was justified by ongoing settlement discussions and the absence of a speedy remedy within the legal framework.
Court of Appeals Decisions
LBP's appeal to the Court of Appeals (CA) was dismissed. The CA stated that the petitioner did not sufficiently explain the failure to comply with the filing rules, thus affirming the RTC's order dismissing the petition. The petitioner’s subsequent motion for reconsideration was also denied, prompting a further escalation to the Supreme Court.
Legal Basis of the Rulings
The Supreme Court underscored the jurisdictional issues regarding the timely filing of petitions under Section 57 of R.A. No. 6657, which bestows original and exclusive jurisdiction to the Special Agrarian Courts over just compensation petitions. The Court reaffirmed that the 15-day appeal period stipulated in Section 11, Rule XIII of the DARAB Rules of Procedure is crucial; thus, LBP's late filing rendered the adjudicator's decision on just compensation final and executory.
Findings on Substantial Justice
While LBP argued for a relaxation of procedural rules in the interests of substantial justice, the Supreme Court reiterated that errors in judgment must not disrupt the finality of decisions unless extraordinarily compelling circumstances arise. I
...continue readingCase Syllabus (G.R. No. 166309-10)
Background of the Case
- This case involves a petition for review on certiorari filed by the Land Bank of the Philippines (LBP) to contest the Decision dated November 12, 2004, and Resolution dated May 11, 2005, of the Court of Appeals (CA).
- The CA had affirmed the Order dated October 25, 2000, of the Regional Trial Court (RTC) of Sorsogon, Branch 52, which dismissed LBP's petition for determination of just compensation due to late filing.
- The respondent, Severino Listana, owned a 246.0561-hectare land in Sorsogon, under Transfer Certificate of Title No. T-20193, which was voluntarily offered for sale under the Comprehensive Agrarian Reform Program (CARP).
Procedural History
- The LBP initially valued 240.9066 hectares of Listana's land at P5,871,689.03, but Listana rejected this amount.
- A summary proceeding was held by the Department of Agrarian Reform (DAR), leading to a decision on October 14, 1998, by DAR Provincial Adjudicator Manuel M. Capellan, which fixed just compensation at P10,956,963.25.
- LBP received this decision on October 27, 1998, and filed a petition for judicial determination of just compensation on September 6, 1999—116 days late.
Arguments of the Parties
Petitioner (LBP):
- Argued that the valuation by the Adjudicator was unacceptable and that its initial valuation was aligned with the law.
- Claimed that the acceptance of the valuation for a portion of the land (151.1419 hectares) constitut