View full case

LAND BANK OF PHILIPPINES v. CA

FACTS:

Elizabeth P. Diaz owned 10 hectares of agricultural land that was expropriated by the Department of Agrarian Reform (DAR) under Presidential Decree No. 27 and Executive Order No. 228. Dissatisfied with the valuation of the land, Elizabeth filed a complaint before the Regional Trial Court (RTC) seeking just compensation of P350,000 per hectare, amounting to a total of P5,250,000. Three Commissioners were appointed to determine the just compensation. The RTC, acting as a Special Agrarian Court (SAC), adopted the DAR's valuation and fixed the just compensation at P19,107.235 per hectare, totaling P197,922.29. Elizabeth's motion for reconsideration was denied, and she appealed the case to the Court of Appeals.

Land Bank of the Philippines (Land Bank) filed a motion to dismiss the appeal, arguing that the proper remedy is a petition for review and not an ordinary appeal. The Court of Appeals denied Land Bank's motion to dismiss. Land Bank then filed a petition for review on certiorari before the Supreme Court, asserting that the SAC decision had become final and executory, and that the Court of Appeals never gained jurisdiction over the appeal.

ISSUES:

  1. Whether the Court of Appeals acquired jurisdiction over the appeal filed by Elizabeth.

  2. Whether the proper mode of appeal from decisions of Regional Trial Courts sitting as Special Agrarian Courts is through an ordinary appeal under Rule 41 or by petition for review under Rule 42.

RULING:

  1. The Court of Appeals did not acquire jurisdiction over the appeal filed by Elizabeth. 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 and not through an ordinary appeal under Rule 41. The decision of the SAC has already become final and executory.

  2. 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. There is no conflict between Section 60 and 61 of RA 6657 as the Rules of Court do not prescribe the procedure for ordinary appeals as the proper mode of appeal for decisions of Special Agrarian Courts.

PRINCIPLES:

  • 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.

  • There is no conflict between Section 60 and 61 of RA 6657 in terms of the proper mode of appeal for decisions of Special Agrarian Courts.