Apo Fruits Corp. v. Land Bank
REITERATIONFacts
The Antecedents: Apo Fruits Corporation (AFC) and Hijo Plantation, Inc. (HPI) sought the determination of just compensation for their lands. The Regional Trial Court (RTC), acting as a Special Agrarian Court (SAC), fixed the just compensation at P1,383,179,000.00, with additional orders for interest, commissioners' fees, and attorney's fees. Procedural History: The Court of Appeals (CA) gave due course to Land Bank of the Philippines' (LBP) appeal. The Supreme Court, in a Decision dated February 6, 2007, partially granted AFC and HPI's petition, affirming the CA's decision to give due course to LBP's appeal, but also affirming the RTC's decision on just compensation. LBP filed an Omnibus Motion for reconsideration, referral to the en banc, and oral argument. In a Resolution dated December 19, 2007, the Third Division partially granted LBP's motion, deleting the 12% interest and attorney's fees, and remanding the case for further hearing on commissioners' fees. LBP and AFC/HPI sought reconsideration of this resolution. LBP filed another Omnibus Motion seeking reconsideration of the denial of its motion to refer the case to the en banc and leave to file a second motion for reconsideration. AFC and HPI filed a Motion for Partial Reconsideration praying for the reinstatement of interest and attorney's fees. LBP also filed an urgent motion for TRO/Writ of Preliminary Injunction to enjoin the execution of the December 19, 2007 Resolution. The Petition: The Supreme Court resolved the pending motions filed by LBP and AFC/HPI.
Issue(s)
Whether the case should be referred to the Supreme Court en banc. Whether LBP is allowed to file a second motion for reconsideration on the issue of just compensation. Whether the award of 12% interest on the balance of just compensation should be reinstated. Whether the award of attorney's fees should be reinstated.
Ruling
The Supreme Court denied with finality the Omnibus Motion for Reconsideration of Land Bank of the Philippines and the Motion for Partial Reconsideration of Apo Fruits Corporation and Hijo Plantation, Inc. The Temporary Restraining Order issued on March 12, 2008, was lifted.
Ratio Decidendi
On the referral to the Supreme Court en banc: The Court held that LBP's argument for referral was without basis. The Third Division's previous resolutions did not modify or reverse established doctrines in Land Bank of the Philippines v. Sps. Banal, Land Bank of the Philippines v. Celada, and Land Bank of the Philippines v. Lim. The RTC, acting as SAC, considered all material and relevant factors in determining just compensation, unlike in the cited cases where the valuation was based on limited factors or without proper hearings. Furthermore, the Court emphasized that a division of the Supreme Court is not inferior to the Court en banc, and its denial of a motion for referral is final and not appealable to the en banc. On the second motion for reconsideration: The Court denied LBP's prayer for leave to file a second motion for reconsideration. It reasoned that LBP had already sought reconsideration of the amount of just compensation in its previous motion, which was denied. A second motion for reconsideration is a prohibited pleading under Rule 52, Section 2 of the Rules of Court, which states that no second motion for reconsideration by the same party shall be entertained. On the reinstatement of interest: The Court found the motion for partial reconsideration of AFC and HPI to be without merit. It reiterated that the reasons for reversing the award of interest were thoroughly discussed in its December 19, 2007 Resolution. Since AFC and HPI failed to present any new arguments, there was no reason to delve further into the issue. The Court had previously deleted the award of 12% interest per annum. On the reinstatement of attorney's fees: Similar to the issue of interest, the Court found the motion for partial reconsideration of AFC and HPI to be without merit. The reasons for deleting the award of attorney's fees were already comprehensively explained in the December 19, 2007 Resolution. The petitioners did not present any new arguments to warrant a reconsideration of this matter.
Main Doctrine
A second motion for reconsideration is a prohibited pleading. A division of the Supreme Court is not inferior to the Court en banc and its rulings on motions for referral are final.