G.R. No. 166298 ; November 17, 2010
LAND BANK OF THE PHILIPPINES, Petitioner, vs. SPOUSES JOEL R. UMANDAP and FELICIDAD D. UMANDAP, Respondents.

FACTS

The spouses Umandap owned agricultural land placed under CARP coverage. The DAR and LBP offered compensation, which was rejected. The DAR Adjudicator fixed just compensation at ₱23,909,608.86. Dissatisfied, LBP filed a Petition for Judicial Determination of Just Compensation with the RTC (Civil Case No. 3750). The RTC dismissed this petition because LBP’s certification against forum shopping was signed by an officer whose authority was not initially proven. LBP’s motion for reconsideration, which attached a confirmation from the LBP President, was denied. LBP then refiled the petition (Civil Case No. 3785), attaching a special power of attorney and board resolution to cure the authority defect.
The spouses Umandap moved to dismiss the refiled case, arguing it was filed beyond the 15-day reglementary period for appealing the Adjudicator’s decision under DARAB rules. The RTC agreed and dismissed the case with prejudice, ruling the Adjudicator’s decision had attained finality. LBP filed a Petition for Certiorari with the Court of Appeals. Initially, the CA granted the petition, but upon reconsideration, it issued an Amended Decision dismissing LBP’s certiorari petition, holding that the RTC’s dismissal order was final and appealable, not correctible by certiorari, and that LBP lost its right to appeal by not timely refiling.

ISSUE

Whether the Court of Appeals erred in dismissing LBP’s Petition for Certiorari and in ruling that the RTC’s dismissal of the refiled petition for judicial determination of just compensation was correct.

RULING

The Supreme Court granted LBP’s petition and reversed the Court of Appeals. The legal logic is anchored on the nature of just compensation proceedings and the proper remedy from an RTC acting as a Special Agrarian Court (SAC). The Court held that an RTC, when acting as a SAC, exercises original and exclusive jurisdiction over petitions for the determination of just compensation. Such a petition is an original action, not an appeal. Therefore, the 15-day period under DARAB rules for appealing an adjudicator’s decision to the Department of Agrarian Reform Adjudication Board (DARAB) does not apply to a judicial petition filed directly with the SAC. The reglementary period for filing such an original action with the RTC is governed by the Rules of Court, not by summary administrative rules. Consequently, LBP’s refiling of its petition was not time-barred. The Court further ruled that the RTC’s dismissal of the original petition (Civil Case No. 3750) for a defective certification was a dismissal without prejudice. LBP’s subsequent refiling with the cured certification was thus a permissible remedy. The RTC’s contrary dismissal order was issued with grave abuse of discretion, making certiorari an appropriate remedy to correct such error.