Land Bank v. Saludanes
REITERATIONFacts
1. The Antecedents: This case originates from twenty-one (21) petitions filed by various landowners seeking just compensation for their landholdings, which form part of a banana plantation operated by AMS Group of Companies. These lands were offered for sale to the government under the Comprehensive Agrarian Reform Program (CARP). The Land Bank of the Philippines (LBP) and the Department of Agrarian Reform (DAR) were impleaded as respondents in these petitions. 2. Procedural History: The Regional Trial Court, Branch 2, Tagum City, acting as a Special Agrarian Court, consolidated the petitions and appointed a panel of Commissioners to determine the just compensation. After trial, the court approved the Commissioners' report and rendered a joint decision on February 7, 2000, fixing the total just compensation at P111,533,686.14, including adjustments for currency value and interest, and ordering the DAR through LBP to pay this amount along with commissioner's fees and attorney's fees. The LBP's motion for reconsideration was denied, and its subsequent Notice of Appeal was also denied due course by the Special Agrarian Court. The DAR also filed a Notice of Appeal which was denied. The joint decision became final and executory on May 3, 2000. 3. The Petition: The Land Bank of the Philippines filed a petition for certiorari with the Court of Appeals (CA-G.R. SP No. 59492) on August 2, 2000. The Court of Appeals dismissed this petition in a Resolution dated November 22, 2000, finding it was filed thirty-two (32) days beyond the sixty (60) day reglementary period prescribed by Section 4, Rule 65 of the 1997 Rules of Civil Procedure. A motion for reconsideration was denied by the Court of Appeals on January 9, 2001. The LBP then filed the instant petition for review on certiorari with the Supreme Court, admitting the late filing but pleading for exemption based on justice and equity, arguing that the Court has the power to suspend its rules for compelling reasons. The Supreme Court denied the petition, holding that no compelling reason was shown and that the payment of the amounts specified in the Special Agrarian Court's decision rendered the case moot and academic.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari filed by the Land Bank of the Philippines for being filed beyond the reglementary period. Whether the Land Bank of the Philippines is entitled to an exemption from the strict application of the 60-day reglementary period for filing a petition for certiorari on grounds of justice and equity.
Ruling
The Supreme Court denied the petition for review on certiorari, affirming the Resolutions of the Court of Appeals. The Court held that the petition was filed beyond the reglementary period and that no compelling reason was presented to justify an extension.
Ratio Decidendi
On the timeliness of the petition for certiorari: The Court reiterated that Section 4, Rule 65 of the 1997 Rules of Civil Procedure, as amended, mandates that a petition for certiorari must be filed not later than sixty (60) days from notice of the judgment, order, or resolution. This period is considered reasonable and sufficient to allow a party to prepare a petition. The Court emphasized that this period is generally non-extendible, except for compelling reasons, and not merely for good and sufficient reason. In the instant case, the petitioner LBP admitted that its petition before the Court of Appeals was filed thirty-two (32) days late. The Court found no compelling reason presented by LBP to warrant an exception to the strict application of the rule. The Court cited Yutingco v. Court of Appeals to underscore the importance of adhering to the reglementary period to avoid unreasonable delay and uphold the constitutional right to a speedy disposition of cases. Therefore, the dismissal by the Court of Appeals was proper. On the plea for exemption based on justice and equity: While acknowledging the Supreme Court's power to suspend its own Rules, the Court found that the petitioner LBP failed to show any compelling reason why it should do so in this instance. The Court noted that LBP had already paid the amounts specified in the joint decision of the Special Agrarian Court, which rendered the case moot and academic. This fact further weakened any argument for leniency based on equity, as the primary objective of the agrarian reform process, which was to compensate the landowners, had already been substantially fulfilled. The Court's power to suspend its rules is not a license to disregard the rules but is to be exercised only in the interest of justice when there is a clear showing of compelling necessity. The mere fact that a party is late in filing does not automatically warrant an exception.
Main Doctrine
The 60-day reglementary period for filing a petition for certiorari under Section 4, Rule 65 of the 1997 Rules of Civil Procedure is non-extendible except for compelling reasons. Failure to file within the said period, absent such compelling reason, warrants the outright dismissal of the petition.