G.R. No. 190660 ; April 11, 2011
LAND BANK OF THE PHILIPPINES, Petitioner, vs. COURT OF APPEALS and ELIZABETH DIAZ, represented by FRANCISCA P. DE GUZMAN as Attorney-in-Fact, Respondents.

FACTS

Private respondent Elizabeth P. Diaz was the registered owner of a 15-hectare agricultural land in Nueva Ecija. Ten hectares were expropriated by the Department of Agrarian Reform (DAR) under the Comprehensive Agrarian Reform Program. The DAR valued the land at ₱197,922.18. Dissatisfied, Diaz, through her attorney-in-fact, filed a complaint before the Regional Trial Court (RTC) of Guimba, Nueva Ecija, Branch 33, acting as a Special Agrarian Court (SAC), praying for just compensation of ₱5,250,000. The SAC, in its Decision dated June 21, 2006, adopted the DAR’s valuation. Diaz’s motion for reconsideration was denied. She then elevated the case to the Court of Appeals via an ordinary appeal (notice of appeal). During the pendency of the appeal, petitioner Land Bank of the Philippines filed a Motion to Dismiss the Appeal, arguing that the proper mode of appeal from SAC decisions is a petition for review under Rule 42 of the Rules of Court, not an ordinary appeal under Rule 41. The Land Bank contended that the filing of the wrong mode of appeal meant the SAC Decision had become final and executory, depriving the appellate court of jurisdiction. The Court of Appeals denied the motion to dismiss. Hence, Land Bank filed the present petition for review on certiorari.

ISSUE

Whether the Court of Appeals erred in not dismissing the appeal and in not declaring the SAC Decision final and executory due to private respondent’s use of the wrong mode of appeal.

RULING

The Supreme Court GRANTED the petition. The Court ruled that the proper mode of appeal from decisions of Regional Trial Courts sitting as Special Agrarian Courts is by petition for review under Rule 42 of the Rules of Court, as expressly provided in Section 60 of Republic Act No. 6657 (Comprehensive Agrarian Reform Law). This was established in the precedent case of Land Bank of the Philippines v. De Leon. The Court harmonized Sections 60 and 61 of R.A. 6657, explaining that Section 61’s reference to the Rules of Court means the procedure for petitions for review (Rule 42) applies suppletorily. The adoption of a petition for review is intended to hasten the resolution of just compensation cases, as prompt payment is an essential component of “just” compensation. Consequently, private respondent Elizabeth Diaz’s resort to an ordinary appeal (notice of appeal) was a fatal procedural error. The filing of a notice of appeal did not toll the reglementary period for filing a petition for review. The perfection of an appeal in the prescribed manner is jurisdictional. Therefore, the SAC Decision dated June 21, 2006, attained finality. The Court of Appeals Resolution dated June 2, 2009, was SET ASIDE, and the SAC Decision was deemed final and executory.