Case Summary (G.R. No. 157903)
Relevant Facts
Federico Suntay was the registered owner of a 3,682.0285-hectare parcel of land in Sta. Lucia, Sablayan, Occidental Mindoro, covered by Transfer Certificate of Title No. T-31. In 1972, the Department of Agrarian Reform (DAR) expropriated 948.1911 hectares of his land pursuant to the government's land reform program under Presidential Decree No. 27. The Land Bank, working with the DAR, valued the expropriated land at P4,251,141.68, which the respondent deemed unreasonably low.
Jurisdictional Challenges
Respondent contested the valuation and sought a determination of just compensation from the Regional Agrarian Reform Adjudicator (RARAD), resulting in a decision that fixed the compensation at P157,541,951.30. The petitioner Land Bank’s attempt to seek judicial determination of just compensation through the Regional Trial Court (RTC) was met with a motion to dismiss by the respondent, claiming it was filed late.
Court Proceedings and Orders
The RTC dismissed petitioner’s petition due to late filing. Following this, the petitioner sought relief through a Notice of Appeal, which was later dismissed on grounds that the proper mode of appeal was a petition for review, according to Section 60 of Republic Act No. 6657 (Comprehensive Agrarian Reform Law). This led the petitioner to file a certiorari petition with the Court of Appeals.
Court of Appeals’ Decision
Initially, the Court of Appeals granted petitioner relief, ordering the RTC to consider the appeal valid. However, upon reconsideration, citing the legal precedent of Land Bank of the Philippines v. Arlene De Leon, the Court rejected the appeal on grounds that the RTC did not err in its dismissal.
Legal Arguments
The petitioner argued that the RTC made a grave abuse of discretion in dismissing the notice of appeal and contended that the RTC acted beyond its jurisdiction by treating the petition for just compensation as an appeal from an RARAD decision. The respondent, conversely, argued that the appeal route taken by the petitioner was incorrect.
Jurisdiction of Special Agrarian Courts
The crucial legal determination involved interpreting the scope of the jurisdiction of the Special Agrarian Courts. The Supreme Court clarified that the RTC has original and exclusive jurisdiction over petitions regarding the determination of just compensation for landowners, as outlined in Section 57 of R.A. No. 6657. This position distinguishes the authority of the DAR and RARAD from that of the RTC when addressing compensation for expropriated properties.
Determination of Just Compensation
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Case Reference and Jurisdiction
- The case is recorded under G.R. No. 157903 and was decided on October 11, 2007, by the First Division of the Supreme Court of the Philippines.
- The decision was penned by Justice Sandoval-Gutierrez.
Parties Involved
- Petitioner: Land Bank of the Philippines
- Respondent: Federico C. Suntay, represented by his assignee, Josefina Lubrica.
- Additional respondents included Hon. Ernesto P. Pagayatan (Executive Judge, RTC, Branch 46, San Jose, Occidental Mindoro), the Department of Agrarian Reform (DAR), and Regional Agrarian Reform Adjudicator Conchita C. MiAas.
Facts of the Case
- Federico Suntay, married to Cristina Aguinaldo-Suntay, is the registered owner of 3,682.0285 hectares of land in Sta. Lucia, Sablayan, Occidental Mindoro, under Transfer Certificate of Title No. T-31.
- In 1972, the DAR expropriated 948.1911 hectares of Suntay's property under Presidential Decree No. 27, primarily consisting of lowland non-irrigated riceland.
- The Land Bank and DAR assessed the expropriated land's value at P4,251,141.68 (approximately P4,497.50 per hectare), which Suntay rejected as insufficient, claiming it was a violation of due process.
- Suntay filed a petition for just compensation with the Office of the Regional Agrarian Reform Adjudicator (RARAD), which ruled in his favor, determining just compensation to be P157,541,951.30 on January 24, 2001.
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