G.R. No. 167952 ; February 1, 2012
GONZALO PUYAT & SONS, INC., Petitioner, vs. RUBEN ALCAIDE (deceased), substituted by GLORIA ALCAIDE, representative of the Farmer-Beneficiaries, Respondent.

FACTS

Petitioner Gonzalo Puyat & Sons, Inc. is the registered owner of several parcels of land in Biñan, Laguna. The Department of Agrarian Reform (DAR) issued a Notice of Coverage and a subsequent Notice of Valuation and Acquisition over the properties for distribution under the Comprehensive Agrarian Reform Program (CARP). Petitioner filed a petition before the DAR, arguing the land was industrial and exempt from CARP. On June 8, 2001, the DAR Secretary issued an Order dismissing the petition and declaring the land agricultural and covered by CARP. Petitioner did not file a motion for reconsideration or an appeal from this Order. Consequently, upon respondents’ motion, the DAR issued an Order of Finality on August 6, 2001.
Petitioner later filed a Motion to Lift Order of Finality and a subsequent Motion for Reconsideration of the June 8, 2001 Order. The DAR denied the motion for reconsideration. Petitioner then appealed to the Office of the President (OP), which reversed the DAR, set aside its orders, and lifted the Notices of Coverage and Acquisition. The OP Decision became final. Respondents then filed a Petition for Relief with the OP, which was dismissed. Respondents elevated the case to the Court of Appeals (CA), which granted the petition and reinstated the DAR Orders, ruling that the OP had no jurisdiction because petitioner failed to appeal the DAR Order to the OP within the reglementary period.

ISSUE

Whether the Court of Appeals erred in ruling that the Office of the President had no jurisdiction to entertain petitioner’s appeal due to the latter’s failure to perfect a timely appeal from the DAR Secretary’s Order.

RULING

Yes, the Supreme Court reversed the Court of Appeals. The Court held that the DAR’s issuance of the Order of Finality on August 6, 2001, was premature and void. The June 8, 2001 DAR Order could not attain finality at that time because petitioner’s period to appeal had not yet lapsed. Under the rules, a party has fifteen (15) days from receipt of a DAR Order to move for reconsideration or appeal to the OP. Petitioner received a copy of the June 8, 2001 Order only on September 4, 2001, via a letter from the DAR Director. Therefore, the 15-day period to appeal commenced only on September 4, 2001. Petitioner filed its appeal with the OP on November 21, 2001, which was within the period, considering the intervening motion for reconsideration filed with the DAR. Since the appeal was timely, the OP validly acquired jurisdiction. The OP’s Decision, having become final and executory, must be reinstated. The Court found no need to discuss the other substantive issues on land classification.