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LAND BANK OF PHILIPPINES v. RAYMUNDA MARTINEZ

FACTS:

This is a case involving a petition for review on certiorari assailing the resolutions of the Court of Appeals (CA). The Department of Agrarian Reform (DAR) acquired respondent Martinez's land in accordance with the Comprehensive Agrarian Reform Law of 1988 (CARL). The Land Bank of the Philippines (LBP) offered just compensation to respondent, but it was rejected. The DARAB conducted summary administrative proceedings to determine just compensation. The Provincial Agrarian Reform Adjudicator (PARAD) rendered a judgment ordering LBP to pay respondent Twelve Million One Hundred Seventy-Nine Thousand Four Hundred Ninety-Two and 50/100 Pesos (Php 12,179,492.50). LBP then filed a petition for the fixing of just compensation before the Special Agrarian Court (SAC). However, respondent moved for the dismissal of the petition, arguing that the orders of the DARAB had become final. Respondent also filed a motion for a writ of execution, which was granted. LBP, on the other hand, filed a motion to quash, but it was denied. Consequently, LBP resorted to filing a petition for certiorari before the CA, which was dismissed due to forum-shopping. The CA not only dismissed the petition but also warned LBP's counsel about the consequences of forum-shopping. LBP's motion for reconsideration was subsequently denied. Dissatisfied with the CA's resolutions, LBP appealed to the Supreme Court, asserting that it did not commit forum-shopping and that the PARAD gravely abused its discretion.

ISSUES:

  1. Whether the Office of the Government Corporate Counsel (OGCC) should participate as the principal law office of Land Bank of the Philippines (LBP)

  2. Whether the LBP Legal Department can independently handle litigations on behalf of LBP

  3. Whether or not the Land Bank of the Philippines (LBP) had the authority to file the petition without the express conformity of the Office of the Government Corporate Counsel (OGCC).

  4. Whether or not LBP engaged in forum shopping.

  5. Whether or not the Office of the Provincial Agrarian Reform Adjudicator (PARAD) gravely abused its discretion in executing the decision for land valuation.

RULING:

  1. The OGCC should participate as the principal law office of LBP. The provision in the Administrative Code of 1987 establishes the proper hierarchical order, with the LBP Legal Department being under the control and supervision of the OGCC. This ensures the role of the OGCC as the principal law office of all government-owned and controlled corporations (GOCCs) is upheld.

  2. The existence of the LBP Legal Department does not render the OGCC a superfluity. While the LBP Legal Department performs vital legal services, it cannot deprive the OGCC of its role as overseer of the LBP Legal Department and its mandate of control and supervision over all GOCC legal departments. The OGCC's participation is required for the purpose of filing petitions and making submissions before the court.

  3. The appeal is denied on the ground that LBP failed to secure the authority of the OGCC to file the petition. Even if LBP was allowed to file the petition without OGCC’s authority, the appeal would still be denied because the Court finds no reversible error in the Court of Appeals (CA) ruling that LBP engaged in forum shopping.

  4. The Court acknowledged that LBP engaged in forum shopping as it simultaneously moved to quash the PARAD resolutions and petitioned for their annulment via certiorari. The Court held that in both proceedings, the parties were identical and the reliefs prayed for were the same. Moreover, the Court noted that conflicting decisions may arise from the different courts involved, which is the evil sought to be avoided by prohibition on forum shopping.

  5. The Court ruled that the PARAD did not gravely abuse its discretion by executing the decision for land valuation. The decision of the Adjudicator on land valuation and preliminary determination and payment of just compensation attains finality after the lapse of the 15-day period. In this case, LBP's petition for the fixing of just compensation was filed 26 days after its receipt of the PARAD's decision, making the latter decision already final and the PARAD's right to issue the writ of execution valid.

PRINCIPLES:

  • The OGCC is the principal law office of GOCCs and exercises control and supervision over the legal departments of GOCCs.

  • The OGCC's involvement in litigations pursued by GOCCs is necessary for the proper implementation of its statutory role and to ensure consistency and non-conflict among GOCCs.

  • The OGCC's participation is required to receive attorney's fees adjudged in favor of GOCCs, as authorized by law.

  • The role of the OGCC as principal law office of GOCCs is part of public policy to ensure a unified legal position and prevent adversarial positions among GOCCs.

  • Any previous practice or individual courts' decision to proceed with litigations handled exclusively by the LBP Legal Department does not negate the OGCC's role and mandate. It can be invoked by adverse parties or courts in the future.

  • The authority of the Office of the Government Corporate Counsel is required for the Land Bank of the Philippines to file a petition.

  • Forum shopping is the practice of litigants resorting to two different fora for the purpose of obtaining the same relief, creating the possibility of conflicting decisions. It is prohibited by law.

  • The decision of the Adjudicator on land valuation becomes final after the lapse of the 15-day period, as provided in the DARAB Rules of Procedure.

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