G.R. No. 148892 ; May 6, 2010
LAND BANK OF THE PHILIPPINES, Petitioner, vs. LUZ L. RODRIGUEZ, Respondent.

FACTS

Respondent Luz L. Rodriguez is the registered owner of agricultural land voluntarily offered for sale under the Comprehensive Agrarian Reform Program (CARP). Dissatisfied with the compensation offered by petitioner Land Bank of the Philippines, Rodriguez filed a petition for determination of just compensation with the Regional Trial Court sitting as a Special Agrarian Court (RTC-SAC). The RTC-SAC rendered a decision fixing the compensation. Landbank filed a motion for reconsideration, which was denied. Landbank then filed a Notice of Appeal, which the RTC-SAC gave due course, forwarding the records to the Court of Appeals (CA).
Rodriguez moved for reconsideration of the order giving due course to the appeal, citing Section 60 of Republic Act No. 6657 , which states that an appeal from a Special Agrarian Court decision is via a petition for review with the CA. The RTC-SAC granted Rodriguez’s motion, declared its decision final and executory, and ordered the return of the records. Rodriguez then filed a motion with the CA to remand the records. The CA granted the motion and dismissed Landbank’s appeal for employing the wrong mode of appeal.

ISSUE

Whether the proper mode of appeal from a decision of the RTC-SAC in a just compensation case is an ordinary appeal (via notice of appeal) or a petition for review.

RULING

The Supreme Court ruled that the proper mode of appeal is a petition for review under Rule 42 of the Rules of Court, not an ordinary appeal under Rule 41. This was settled in Land Bank of the Philippines v. De Leon. The legal logic is rooted in the nature of just compensation and the need for expediency. Just compensation requires not only correctness in amount but also prompt payment. A petition for review, which dispenses with procedural steps like filing a notice of appeal and waiting for the completion of records, offers a more direct and faster route to appellate review. This expedited process aligns with the constitutional imperative that payment for property taken must be made within a reasonable time; undue delay renders the compensation unjust.
However, the Court applied this ruling prospectively from March 20, 2003, as clarified in a subsequent resolution in De Leon. Since Landbank filed its notice of appeal on August 18, 1998—prior to March 20, 2003—its appeal was filed during the period when the procedural rule was unsettled. Therefore, the dismissal by the CA was improper. The Court reinstated Landbank’s appeal and remanded the case to the CA for proper disposition on the merits, applying the rules in effect at the time the appeal was taken.