Land Bank v. Martinez
REITERATIONFacts
The Antecedents: The Department of Agrarian Reform (DAR) compulsorily acquired 62.5369 hectares of land owned by respondent Raymunda Martinez. The Land Bank of the Philippines (LBP) offered P1,955,485.60 as just compensation, which Martinez rejected, deeming it unjust. Consequently, the Department of Agrarian Reform Adjudication Board (DARAB), through its Provincial Agrarian Reform Adjudicator (PARAD), initiated administrative proceedings to determine just compensation. The PARAD, finding inconsistencies in LBP's computation, ultimately ordered LBP to pay Martinez P12,179,492.50. Procedural History: Following the PARAD's decision, LBP filed a petition for the fixing of just compensation with the Special Agrarian Court (SAC). Martinez moved to dismiss this petition, arguing it was filed out of time. Concurrently, Martinez sought a writ of execution from the PARAD based on its earlier decision. The PARAD granted the writ of execution, finding LBP's petition to the SAC was filed 26 days after receipt of the PARAD's decision, exceeding the 15-day period for appeal. LBP then moved to quash this resolution, and subsequently filed a petition for certiorari with the Court of Appeals (CA), assailing both PARAD resolutions. The CA dismissed LBP's certiorari petition for forum-shopping, a decision later affirmed upon denial of LBP's motion for reconsideration. The Petition: LBP filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's dismissal of its certiorari petition. LBP argued that it did not commit forum-shopping, as its filing with the PARAD was a motion to quash, not an initiatory pleading, and that the PARAD's decision was not yet final due to the pending petition before the SAC. LBP also contended that its legal department had the authority to file the petition. The Supreme Court, however, denied the appeal, primarily finding that LBP lacked the authority to file the petition as the Office of the Government Corporate Counsel (OGCC) is LBP's principal law office, and that LBP did indeed commit forum-shopping by filing a certiorari petition while a motion to quash was pending. Furthermore, the Court found that the PARAD did not gravely abuse its discretion in issuing the writ of execution, as LBP's petition with the SAC was filed beyond the reglementary period, rendering the PARAD's decision final.
Issue(s)
Whether petitioner Land Bank of the Philippines may file the instant appeal solely through its legal department. Whether petitioner Land Bank of the Philippines committed forum shopping. Whether the PARAD gravely abused its discretion when it issued a writ of execution despite the pendency of LBP's petition for fixing of just compensation with the SAC.
Ruling
The Supreme Court denied the appeal and affirmed the decision of the Court of Appeals. The Court held that LBP's appeal was without merit on multiple grounds.
Ratio Decidendi
On the authority of LBP's Legal Department to file the appeal: The Court ruled that the Land Bank of the Philippines (LBP) cannot file petitions before courts or quasi-judicial bodies solely through its Legal Department. Section 10, Book IV, Title III, Chapter 3 of the Administrative Code of 1987 mandates the Office of the Government Corporate Counsel (OGCC) to act as the principal law office of all government-owned or controlled corporations (GOCCs), including LBP. The LBP Legal Department is under the control and supervision of the OGCC. The Court noted that the OGCC did not enter its appearance as principal legal counsel for LBP, nor did it give its conformity to the filing of the petition by the LBP Legal Department. This lack of authority, on its own, was sufficient ground to deny the appeal. The Court emphasized that years of incorrect practice do not legitimize a statutory violation and that the OGCC's role as principal law office is a matter of public policy. On whether petitioner committed forum shopping: The Court affirmed the CA's finding that LBP committed forum shopping. The Court reiterated the definition of forum shopping as resorting to two different fora for the purpose of obtaining the same relief, creating the possibility of conflicting decisions. In this case, LBP filed a motion to quash the PARAD resolutions with the PARAD and simultaneously filed a petition for certiorari with the CA assailing the same resolutions. The parties were identical, the reliefs prayed for were the same, and the singular stance of LBP in both proceedings was that the PARAD resolutions should not be executed. This situation presented the evil sought to be avoided by the rule against forum shopping, which is the possibility of conflicting rulings from different fora. On whether the PARAD gravely abused its discretion in issuing the writ of execution: The Court found that the PARAD did not gravely abuse its discretion. Rule XIII, Section 11 of the DARAB Rules of Procedure provides that decisions on land valuation and preliminary determination of just compensation are not appealable to the Board but must be brought directly to the Special Agrarian Courts (SACs) within fifteen (15) days from receipt of notice. Any party is entitled to only one motion for reconsideration. The Court has consistently held that the adjudicator's decision attains finality after the lapse of the 15-day period. In this case, LBP filed its petition with the SAC 26 days after receiving the PARAD's decision, which was eleven days beyond the reglementary period. Therefore, the PARAD's decision had already attained finality, and the PARAD was well within its authority to issue the writ of execution.
Main Doctrine
The Land Bank of the Philippines (LBP) cannot file petitions before courts or quasi-judicial bodies solely through its Legal Department; the Office of the Government Corporate Counsel (OGCC) must act as its principal law office. Furthermore, filing a petition for certiorari while a motion to quash the same order is pending before a lower court constitutes forum shopping. A decision of the Provincial Agrarian Reform Adjudicator (PARAD) on land valuation attains finality after 15 days if no appeal is filed with the Special Agrarian Court (SAC) within the reglementary period.