GR 204526; (February, 2021) (Digest)
G.R. No. 204526 , February 10, 2021.
Land Bank of the Philippines, Petitioner, vs. Espedito Q. Escaro, represented by Marcelo Q. Escaro, Sr., Respondent.
FACTS
The Department of Agrarian Reform placed 24.0467 hectares of land owned by respondent’s predecessor under compulsory acquisition. Petitioner Land Bank of the Philippines valued the property at P272,347.63. Respondent rejected this valuation. The matter was referred to the Provincial Agrarian Reform Adjudicator, who fixed just compensation at P1,555,084.00. Petitioner elevated the case to the Department of Agrarian Reform Adjudication Board, which reversed the PARAD and reinstated petitioner’s valuation. Respondent received the DARAB Decision on May 7, 2008, filed a motion for reconsideration on May 20, 2008, which was denied. Respondent received the denial order on December 16, 2008. On January 5, 2009, respondent filed a complaint with the Regional Trial Court sitting as a Special Agrarian Court to fix just compensation at P1,681,199.00. The RTC-SAC dismissed the complaint on the ground of res judicata, finding that respondent’s filing of a motion for reconsideration with the DARAB did not toll the 15-day period to file an original action with the RTC-SAC under the DARAB Rules, and that respondent’s failure to file a Notice of Filing of Original Action and submit a certified copy of the complaint to the DARAB rendered the DARAB Decision final. The Court of Appeals reversed the RTC-SAC, declaring its orders null and void and directing it to give due course to the complaint. Petitioner sought review, arguing the CA misapplied the law.
ISSUE
Whether the Court of Appeals correctly set aside the RTC-SAC’s dismissal and directed it to proceed with respondent’s action for determination of just compensation, despite respondent’s alleged procedural lapses of filing a motion for reconsideration with the DARAB and not filing a Notice of Filing of Original Action under the DARAB Rules.
RULING
The Supreme Court denied petitioner’s petition, affirming the Court of Appeals. The Court held that the RTC-SAC has original and exclusive jurisdiction over petitions for determination of just compensation. The filing of a motion for reconsideration from the DARAB decision is allowed under Section 51 of Republic Act No. 6657 and the DARAB Rules, and such filing tolls the 15-day period to file an original action with the RTC-SAC. The period should be reckoned from respondent’s receipt of the order denying the motion for reconsideration. The requirement of filing a Notice of Filing of Original Action under the DARAB Rules is merely directory and non-compliance does not affect the jurisdiction of the RTC-SAC nor render the DARAB decision final. The action for determination of just compensation is an original action, not an appeal from the DARAB. The DARAB’s valuation is only preliminary, and the landowner’s right to seek judicial determination prescribes in ten years. The RTC-SAC erred in dismissing the complaint on procedural grounds.