G.R. No. 167952, July 5, 2017
GONZALO PUYAT & SONS, INC., Petitioner, vs. RUBEN ALCAIDE (deceased), substituted by GLORIA ALCAIDE, representative of the Farmer-Beneficiaries, Respondent.

FACTS

This case involves a Resolution of the Supreme Court’s Third Division denying petitioner Gonzalo Puyat & Sons, Inc.’s (GPSI) Omnibus Motion for Reconsideration. The motion sought to set aside the Court’s October 19, 2016 Resolution, which affirmed the coverage of GPSI’s landholdings under the Comprehensive Agrarian Reform Program (CARP). GPSI argued that the Department of Agrarian Reform’s (DAR) June 8, 2001 Order, which declared the land subject to CARP, did not attain finality and that the DAR failed to comply with the preliminary ocular inspection requirements under DAR Administrative Order No. 1, Series of 1998, violating its right to due process.
The procedural history shows GPSI contested the DAR’s jurisdiction, claiming the land was reclassified as industrial. The DAR’s June 8, 2001 Order denied GPSI’s petition for exemption. GPSI’s subsequent motion for reconsideration was filed late, and the DAR had already issued an Order of Finality. GPSI appealed to the Office of the President (OP), which initially ruled in its favor, but the Court of Appeals later reinstated the DAR’s coverage order, a decision ultimately affirmed by the Supreme Court.

ISSUE

The core issues for resolution were: (1) whether the DAR’s June 8, 2001 Order had attained finality, and (2) whether the DAR’s alleged non-compliance with procedural requirements for ocular inspection violated GPSI’s constitutional right to due process.

RULING

The Supreme Court denied the Omnibus Motion, affirming its prior Resolution. On the first issue, the Court held the DAR Order dated June 8, 2001, had indisputably attained finality. The Court provided three legal justifications. First, GPSI’s motion for reconsideration was filed on September 14, 2001, beyond the 15-day reglementary period, as its counsel admitted receiving the Order by August 17, 2001. Second, GPSI’s counsel failed to notify the DAR of a change of address, leading the DAR to correctly deem the Order served on August 3, 2001. This neglect by counsel is binding on the client. Third, the principle that “actual knowledge is equivalent to notice” applied. GPSI’s filing of a “Motion to Lift Order of Finality” on August 20, 2001, which quoted the dispositive portion of the June 8 Order, proved it had actual knowledge of the denial, starting the reglementary period. The belated filing thus rendered the Order final and executory, beyond the OP’s appellate jurisdiction.
On the second issue, the Court found the DAR substantially complied with procedural requirements. The existence of a signed CARP Form No. 3.a (Preliminary Ocular Inspection Report) created a presumption of regularity in the performance of official duty. The mere failure to mark certain checkboxes in the report was deemed inadvertence, not proof of a lack of inspection or a due process violation. The Court also rejected GPSI’s claim of land reclassification, noting a Sangguniang Bayan resolution was insufficient without DAR approval under Section 65 of RA 6657, and a tax declaration marked “proposed industrial” did not constitute actual reclassification. Finally, the Court denied GPSI’s alternative prayer to refer the motion to the Court En Banc, citing jurisprudence that a Division’s denial of such referral is final.