G.R. No. 161090 & 161092; July 4, 2012
SPOUSES ROMEO LL. PLOPENIO and ROSIELINDA PLOPENIO and EDUARDO LL. PLOPENIO, represented by GAVINO PLOPENIO, Petitioners, vs. DEPARTMENT OF AGRARIAN REFORM and LAND BANK OF THE PHILIPPINES, Respondents.

FACTS

Petitioners, landowners in Camarines Sur, offered their coconut lands for acquisition under the Comprehensive Agrarian Reform Program. Dissatisfied with the valuation set by the Land Bank of the Philippines, they rejected the notices and elevated the matter to the Provincial Agrarian Reform Adjudicator (PARAD). The PARAD affirmed Land Bank’s valuation in a Decision received by petitioners on September 27, 2002. They filed a Motion for Reconsideration on October 11, 2002, which was denied by the PARAD in an Order received on December 21, 2002. On January 6, 2003, petitioners filed separate Petitions before the Regional Trial Court (RTC) acting as a Special Agrarian Court (SAC). The SAC-RTC dismissed the petitions, ruling they were filed out of time and that the PARAD Decision had attained finality. Petitioners then filed Petitions for Review directly with the Supreme Court.

ISSUE

The primary issue is whether petitioners correctly filed their appeal from the SAC-RTC Decision directly with the Supreme Court via a Rule 45 Petition for Review.

RULING

The Supreme Court dismissed the petitions for employing a wrongful mode of appeal. The legal logic is anchored on the statutory and exclusive appeal procedure prescribed by Section 60 of Republic Act No. 6657, the Comprehensive Agrarian Reform Law. This provision explicitly states that an appeal from a decision of a Special Agrarian Court is taken by filing a petition for review with the Court of Appeals within fifteen days. The law makes no distinction between appeals raising questions of fact, questions of law, or mixed questions. The Court emphasized that the right to appeal is statutory, and parties must comply with the specific manner provided by the governing law. The general rule that pure questions of law from RTC decisions may be appealed directly to the Supreme Court does not apply to decisions rendered by RTCs exercising their special jurisdiction as SACs. The special agrarian jurisdiction and its corresponding appellate route are governed solely by the CARP law. Consequently, the only permissible mode of appeal from a SAC decision is a petition for review filed with the Court of Appeals under Rule 42 of the Rules of Court. Since petitioners bypassed the Court of Appeals, their direct recourse to the Supreme Court was procedurally infirm. The Court also noted, obiter dictum, that even if the appeal were properly taken, the SAC correctly dismissed the case for being filed out of time, as the 15-day period to appeal from the PARAD decision was not tolled by the filing of a motion for reconsideration under the applicable DARAB rules.