GR 157903; (October, 2007) (Digest)
G.R. No. 157903 . October 11, 2007.
LAND BANK OF THE PHILIPPINES, petitioner, vs. FEDERICO C. SUNTAY, Represented by his Assignee, JOSEFINA LUBRICA, respondent.
FACTS
Respondent Federico Suntay owned a 3,682-hectare land, 948 hectares of which were expropriated in 1972 under P.D. No. 27. The Land Bank of the Philippines (LBP) and the DAR initially valued the land at P4.25 million. Suntay rejected this valuation and filed a petition with the Regional Agrarian Reform Adjudicator (RARAD), which subsequently fixed just compensation at P157.54 million. LBP then filed a Petition for Judicial Determination of Just Compensation with the Regional Trial Court (RTC), acting as a Special Agrarian Court (SAC). The RTC dismissed LBP’s petition for being filed beyond the 15-day reglementary period from the RARAD decision.
LBP filed a Notice of Appeal from the RTC’s dismissal order. The RTC, however, dismissed this notice, ruling that the proper mode of appeal from an SAC decision is a petition for review with the Court of Appeals under Section 60 of R.A. No. 6657 . LBP elevated the matter to the Court of Appeals via a petition for certiorari, arguing the RTC committed grave abuse of discretion. The CA initially granted LBP’s petition but, upon reconsideration, reversed itself and dismissed the petition, affirming that an appeal from the SAC must be by petition for review.
ISSUE
Whether the Court of Appeals erred in ruling that the proper mode of appeal from a decision or final order of the Regional Trial Court, sitting as a Special Agrarian Court, is a petition for review and not a mere notice of appeal.
RULING
No, the Court of Appeals did not err. The Supreme Court affirmed that the correct mode of appeal from decisions or final orders of the RTC acting as a Special Agrarian Court is a petition for review filed with the Court of Appeals. This is explicitly mandated by Section 60 of the Comprehensive Agrarian Reform Law ( R.A. No. 6657 ), which states that an appeal may be taken by filing a petition for review with the Court of Appeals within fifteen days. The Court clarified that while the SAC exercises original and exclusive jurisdiction over all petitions for the determination of just compensation, its decisions are not appealable via ordinary appeal or notice of appeal under the Rules of Court. The special law ( R.A. No. 6657 ) provides a specific rule of procedure that prevails over the general rules. Consequently, the RTC correctly dismissed LBP’s notice of appeal for being an improper mode. The Court further held that the RARAD’s decision does not attain finality as it is merely preliminary; the SAC exercises original and exclusive jurisdiction to determine just compensation with finality. The case was remanded to the RTC for proper proceedings.