Land Bank v. Natividad
REITERATIONFacts
The Antecedents: Private respondents filed a petition before the trial court seeking the determination of just compensation for their agricultural lands in Arayat, Pampanga, which were acquired by the government under the land reform program pursuant to Presidential Decree No. 27 (PD 27). The petition named the Department of Agrarian Reform (DAR) and petitioner Land Bank of the Philippines (Land Bank) as respondents, and was later amended to implead the registered tenants as co-respondents. After trial, the Regional Trial Court (RTC) ordered the DAR and Land Bank to pay private respondents P30.00 per square meter as just compensation for the acquired lands. Procedural History: Following the RTC's Decision, the DAR and Land Bank filed separate motions for reconsideration, which were denied by the RTC for being pro forma due to the absence of a notice of hearing. This failure to file a timely appeal led Land Bank to file a Petition for Relief from Order, citing excusable negligence due to its counsel's heavy workload, which allegedly caused the omission of the notice of hearing. The RTC denied this petition, finding the negligence not excusable. Land Bank then filed the instant Petition for Review before the Supreme Court, assailing the denial of its petition for relief and raising substantive issues regarding the determination of just compensation. The Petition: In its Petition for Review, Land Bank argues that its counsel's failure to include a notice of hearing in the motion for reconsideration constituted excusable negligence, and that the denial of its petition for relief was erroneous. Land Bank also contends that private respondents failed to exhaust administrative remedies by directly filing a petition for just compensation with the trial court, and that the trial court erred in its valuation of the properties, arguing that compensation should be based on the value at the time of acquisition in 1972, not the time of possession in 1993. Land Bank further asserts that PD 27 and Executive Order No. 228, not Republic Act No. 6657, should govern the determination of just compensation.
Issue(s)
Whether the failure of Land Bank's counsel to include a notice of hearing in the motion for reconsideration constitutes excusable negligence. Whether private respondents failed to exhaust administrative remedies. Whether the RTC erred in its determination of just compensation.
Ruling
The petition is denied. The Decision of the RTC ordering the payment of just compensation became final and executory due to Land Bank's failure to file a timely appeal, which stemmed from its counsel's negligence in filing a pro forma motion for reconsideration.
Ratio Decidendi
On the issue of excusable negligence: The Court held that the failure of Land Bank's counsel to include a notice of hearing in the motion for reconsideration, even if attributed to a heavy workload, does not constitute excusable negligence. Excusable negligence must be that which ordinary diligence and prudence could not have guarded against. Counsel's admission of merely scanning and signing the motion without noticing the absence of a notice of hearing demonstrated arrant negligence, especially for a lawyer with considerable experience. A motion lacking a notice of hearing is considered a mere scrap of paper, and the clerk of court has no duty to act upon it. Therefore, the trial court correctly considered the motion pro forma, and the subsequent denial of the motion for reconsideration and the petition for relief from judgment was proper. Procedural rules are meant to be followed strictly, and their relaxation is only for justifiable causes and demonstrable merit, not as a shield for violating rules with impunity. On the issue of exhaustion of administrative remedies: The Court found that private respondents did not fail to exhaust administrative remedies. Records showed that private respondents had written to the DAR Secretary objecting to the land valuation and requesting a conference, but this letter remained unanswered. This prompted them to file a petition directly with the trial court. Furthermore, the Court clarified that while the DAR has primary jurisdiction to determine just compensation administratively, this determination is subject to judicial review. The RTC's original and exclusive jurisdiction over petitions for the determination of just compensation is well-established, and there is no contradiction between administrative and judicial proceedings in this regard. On the issue of just compensation: The Court rejected Land Bank's argument that just compensation should be based on the value of the property as of October 21, 1972, the effectivity of PD 27. Citing jurisprudence, the Court held that the seizure of the landholding does not take place until payment of just compensation. Given that the agrarian reform process was incomplete and Republic Act No. 6657 (RA 6657) was enacted before its completion, just compensation must be determined under RA 6657, with PD 27 and Executive Order No. 228 (EO 228) having only suppletory effect. Section 17 of RA 6657 provides the guideposts for determining just compensation, including acquisition cost, current value of like properties, nature, use, income, sworn valuation, tax declarations, and assessments, as well as social and economic benefits and non-payment of taxes or loans. The Court found that the RTC correctly determined the just compensation based on these factors, considering the land's nature, location, market value, assessor's value, and produce.
Main Doctrine
The failure of counsel to include a notice of hearing in a motion for reconsideration, even if due to heavy workload, constitutes arrant negligence and does not qualify as excusable negligence, rendering the motion pro forma and the subsequent judgment final and executory.