GR 184282; (April, 2012) (Digest)
G.R. No. 184282; April 11, 2012
FRANCISCO SORIANO AND DALISAY SORIANO, Petitioners, vs. REPUBLIC OF THE PHILIPPINES, Respondent.
FACTS
Petitioners Francisco and Dalisay Soriano were the registered owners of two parcels of agricultural land compulsorily acquired by the government under the Comprehensive Agrarian Reform Law (R.A. No. 6657). The Land Bank of the Philippines (LBP) made a preliminary valuation, which the petitioners contested. The Department of Agrarian Reform Adjudication Board (DARAB) affirmed the LBP’s valuation in separate decisions.
Notices of these DARAB decisions were received by petitioners’ counsel on February 22 and March 8, 2001. However, petitioners filed a petition for judicial determination of just compensation before the Regional Trial Court (RTC), acting as a Special Agrarian Court (SAC), only on April 6, 2001. The Department of Agrarian Reform (DAR) moved to dismiss the petition for being filed beyond the 15-day reglementary period prescribed under Section 11, Rule XIII of the 1994 DARAB Rules of Procedure. The RTC denied the motion, ruling that the DARAB rules must yield to the Civil Code’s prescription laws.
ISSUE
Whether the Court of Appeals erred in granting the DAR’s petition for certiorari and dismissing the case for being filed out of time.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The RTC, acting as SAC, committed grave abuse of discretion in not dismissing the case for late filing. The 15-day period to appeal the DARAB’s preliminary valuation to the SAC, as provided in the 1994 DARAB Rules, is mandatory and jurisdictional. This rule finds statutory support in Section 50 of R.A. No. 6657, which grants the DAR primary jurisdiction to determine agrarian disputes, and Section 57, which vests the SAC with original and exclusive jurisdiction over all petitions for the determination of just compensation.
The Court emphasized that the determination of just compensation for agrarian reform purposes is a special proceeding distinct from ordinary civil actions; thus, the ordinary rules on prescription under the Civil Code do not apply. The statutory and regulatory framework establishes a specific, expedited process. Petitioners failed to show any compelling reason to relax the 15-day rule, as their delay was attributable merely to their former counsel’s negligence. Consequently, the SAC did not acquire jurisdiction over the untimely petition. The Court of Appeals correctly annulled the RTC’s orders for having been issued with grave abuse of discretion.