GR 168105; (July, 2011) (Digest)
G.R. No. 168105 ; July 27, 2011
LAND BANK OF THE PHILIPPINES, Petitioner, vs. SEVERINO LISTANA, Respondent.
FACTS
Respondent Severino Listana is the owner of a 246.0561-hectare land in Casiguran, Sorsogon, voluntarily offered for sale under the CARP. Petitioner Land Bank of the Philippines (LBP) valued 240.9066 hectares for acquisition at ₱5,871,689.03, which respondent rejected. The DAR Adjudicator (PARAD) rendered a decision on October 14, 1998, fixing just compensation at ₱10,956,963.25. LBP received a copy on October 27, 1998. Almost a year later, on September 6, 1999, LBP filed a petition for judicial determination of just compensation before the Regional Trial Court (RTC) sitting as a Special Agrarian Court (SAC). Respondent moved to dismiss, arguing the petition was filed late and that his prior acceptance of the DAR’s valuation for a portion of the land (151.1419 hectares) constituted a binding contract and res judicata. The RTC initially denied the motion to dismiss but later granted reconsideration and dismissed the petition on October 25, 2000, for late filing. LBP’s motion for reconsideration was denied. LBP appealed to the Court of Appeals, which affirmed the RTC’s dismissal. LBP then elevated the case to the Supreme Court via a petition for review on certiorari.
ISSUE
Whether the Special Agrarian Court correctly dismissed LBP’s petition for judicial determination of just compensation for having been filed out of time.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ decision. The SAC correctly dismissed LBP’s petition for judicial determination of just compensation for being filed beyond the 15-day reglementary period prescribed by law.
The Court held that the original and exclusive jurisdiction to determine just compensation for lands acquired under the CARP is vested in the SAC. However, this jurisdiction is not automatically invoked. A party must first file a petition for the fixing of just compensation with the SAC within 15 days from receipt of the notice of the DAR Adjudicator’s decision, as mandated by DAR Administrative Order No. 6, Series of 1994. This 15-day period is jurisdictional. Failure to comply results in the DARAB decision becoming final and executory.
In this case, LBP received the PARAD’s decision on October 27, 1998, but filed its petition with the SAC only on September 6, 1999, nearly a year later. This was a clear violation of the 15-day rule. The Court rejected LBP’s arguments for liberal application of procedural rules, emphasizing that the statutory period is mandatory. The Court also noted that the principle of liberality cannot be invoked when a party’s own negligence caused the delay. Consequently, the PARAD’s decision had attained finality and could no longer be disturbed by the SAC. The dismissal of the petition for late filing was proper.