GR 158464; (August, 2016) (Digest)
G.R. No. 158464 , August 02, 2016
JOCELYN S. LIMKAICHONG, PETITIONER, VS. LAND BANK OF THE PHILIPPINES, DEPARTMENT OF AGRARIAN REFORM, RESPONDENTS.
FACTS
Petitioner Jocelyn Limkaichong was the registered owner of agricultural lands placed under the coverage of the Comprehensive Agrarian Reform Program (CARP). The Department of Agrarian Reform Adjudication Board (DARAB) issued Notices of Land Valuation and Acquisition in 1998. After she rejected the valuations, the DARAB conducted summary proceedings and issued an order on May 28, 1999, affirming the valuations. On August 19, 1999, beyond the 15-day statutory period, Limkaichong filed a complaint for judicial determination of just compensation before the Regional Trial Court (RTC) sitting as a Special Agrarian Court (SAC).
The respondents, Land Bank and DAR, moved to dismiss the complaint on the ground that the DARAB order had become final and executory due to the petitioner’s failure to appeal within the reglementary period. The RTC granted the motion to dismiss, citing Section 51 of Republic Act No. 6657 and applicable rules. Limkaichong then filed a petition for certiorari with the Court of Appeals (CA), assailing the dismissal. The CA dismissed the petition, ruling that certiorari was not the proper remedy as the RTC order was a final order appealable by ordinary appeal, and that the RTC committed no grave abuse of discretion.
ISSUE
Whether the Court of Appeals erred in dismissing the petition for certiorari and in affirming the dismissal of the complaint for judicial determination of just compensation.
RULING
The Supreme Court granted the petition, reversed the CA decision, and reinstated the complaint for just compensation. The Court held that the RTC, sitting as a Special Agrarian Court (SAC), has original and exclusive jurisdiction over all petitions for the determination of just compensation. This jurisdiction is conferred by Section 57 of R.A. No. 6657 . The Court clarified that the SAC’s jurisdiction is not appellate but original. Therefore, the 15-day period for appealing an administrative decision under Section 51 of the law does not apply to a landowner’s original action for judicial determination of just compensation filed directly with the SAC.
The legal logic is that the administrative valuation process is merely preliminary. The landowner’s acceptance of the offered compensation is not required for the government to take possession. The SAC is tasked with making the final, authoritative determination of just compensation, which is a judicial function. Filing a petition before the SAC is not an appeal from the DARAB order but the initiation of the judicial process for that determination. Consequently, the timeliness of such a petition is governed by the rules on civil actions, not by the 15-day period for administrative appeals. The RTC thus erred in dismissing the complaint on grounds of prescription, and the CA erred in not correcting this mistake. The case was remanded to the RTC for the proper determination of just compensation.