G.R. No. 158270 ; July 21, 2008
LAND BANK OF THE PHILIPPINES, Petitioner, vs. HERMIN ARCEO, ROMEO L. SANTOS, MACARIO A. IGNACIO, AGNES D.C. MARQUEZ and RODEL V. DELA CRUZ, Respondents.

FACTS

Respondent Hermin Arceo voluntarily offered his 7.9842-hectare agricultural land in Nueva Ecija for sale under the Comprehensive Agrarian Reform Program (CARP) in 1998. The Land Bank of the Philippines (LBP) valued the property at ₱376,379.18. Arceo rejected this valuation, leading to proceedings before the Department of Agrarian Reform Adjudication Board (DARAB), which fixed just compensation at ₱8,577,048.75. LBP sought judicial intervention with the Regional Trial Court (RTC), acting as a Special Agrarian Court. On October 30, 2001, the RTC rendered a decision ordering LBP to pay Arceo ₱11,684,459.85 as just compensation, with legal interest.
LBP moved for reconsideration, which was denied. It then filed a notice of appeal under Rule 41 of the Rules of Court. The Court of Appeals (CA) dismissed this notice of appeal in a Resolution dated January 7, 2003, ruling it was an improper mode of remedy. The CA held that under Section 60 of R.A. No. 6657 (CARP Law), the correct mode of appeal from an RTC decision in a just compensation case is a petition for review under Rule 43. LBP’s motion for reconsideration was denied on May 8, 2003, prompting this petition for review on certiorari.

ISSUE

Whether the Court of Appeals correctly dismissed LBP’s appeal from the RTC decision.

RULING

The Supreme Court denied the petition, but on a different ground: the finality and immutability of the RTC judgment due to LBP’s tardy appeal. The Court clarified that while the CA correctly identified the proper mode of appeal as a petition for review under Rule 43, the more fundamental reason for dismissal was that the RTC decision had already become final and executory. The Court, in Land Bank v. De Leon, had ruled that a petition for review is the proper remedy from an RTC decision acting as a Special Agrarian Court. However, this ruling was applied prospectively from March 20, 2003. For cases decided before this date, like the present one, the old rule—permitting an ordinary appeal via notice of appeal—applied.
Nevertheless, LBP’s appeal was still fatally late. The RTC decision was received by LBP on December 3, 2001. It had only 15 days, or until December 18, 2001, to file an appeal. LBP filed its notice of appeal only on January 2, 2002, clearly beyond the reglementary period. No motion for extension of time to appeal was filed. Consequently, the RTC decision became final and executory by operation of law. A final and executory judgment is immutable and unalterable. The Court emphasized the constitutional mandate for prompt payment of just compensation and noted that Arceo had waited over a decade. Thus, the dismissal of LBP’s appeal was proper due to its untimeliness, rendering the RTC decision final and requiring payment in accordance therewith.