GR 226650; (July, 2020) (Digest)
G.R. No. 226650 , July 08, 2020
LAND BANK OF THE PHILIPPINES, PETITIONER, VS. HEIRS OF RENE DIVINAGRACIA, SUBSTITUTED BY HIS HEIRS, NAMELY: TRANQUILINO RENE, EMORY JUDSON IGNACIO, FELECIANO AND GINA, ALL SURNAMED DIVINAGRACIA, ALL REPRESENTED BY TRANQUILINO RENE DIVINAGRACIA AND SOFIA DIVINAGRACIA, RESPONDENTS.
FACTS
Spouses Rene Divinagracia and Sofia Castro owned 8.8 hectares of agricultural land covered by Operation Land Transfer under Presidential Decree No. 27. Land Bank approved their land transfer claim for compensation at P133,200.00, intended to settle their loan obligation with the Philippine National Bank (PNB) secured by a mortgage on the property. Due to a disagreement over the payment order and its delay, the spouses requested Land Bank to stop payment and withdraw their land from the Operation Land Transfer coverage. This request was denied, prompting the spouses to file a complaint before the Regional Trial Court (RTC) for nullification of the agreement and withdrawal of the property from coverage. Land Bank filed a Motion to Dismiss on jurisdictional grounds, arguing that the Department of Agrarian Reform had jurisdiction, but the RTC denied the motion. The RTC later ruled in favor of the spouses, nullifying the agreements, ordering the land’s withdrawal, and awarding damages. The Court of Appeals (CA) reversed the RTC’s decision, dismissing the complaint for annulment and withdrawal but ordering Land Bank to pay the PNB the P133,200.00 portion of the spouses’ loan. Land Bank filed a Petition for Review, challenging the CA’s jurisdiction and application of law.
ISSUE
Whether the Regional Trial Court (RTC) had jurisdiction over the complaint for the withdrawal of the land from the coverage of Operation Land Transfer.
RULING
The Supreme Court denied the petition, affirming the CA’s Decision and Resolution. The Court held that the issue of the RTC’s jurisdiction had already been conclusively resolved and was barred by the principle of the “law of the case.” The CA, in a prior proceeding (a petition for certiorari filed by Land Bank), had upheld the RTC’s jurisdiction, and that decision had become final. The principle of the law of the case dictates that a rule of law established by an appellate court in a case becomes binding and cannot be departed from in subsequent proceedings in the same case. Therefore, the Court could not re-litigate the jurisdictional issue. Regarding Land Bank’s liability, the Court affirmed the CA’s order for Land Bank to pay the P133,200.00 to PNB, as this obligation arose from the valid compulsory purchase agreement under the agrarian reform program, which Land Bank was bound to fulfill.