Land Bank of the Philippines v. Diaz
REITERATIONFacts
1. The Antecedents: Private respondent Elizabeth P. Diaz owned a 15-hectare agricultural land. Ten hectares of this land were expropriated by the Department of Agrarian Reform (DAR) and valued at ₱197,922.18. Dissatisfied with this valuation, Diaz, through her attorney-in-fact, filed a complaint seeking just compensation fixed at ₱350,000 per hectare, totaling ₱5,250,000. 2. Procedural History: The complaint was filed before the Regional Trial Court of Guimba, Nueva Ecija, Branch 33, acting as a Special Agrarian Court (SAC). The SAC, after appointing commissioners, adopted the DAR's valuation, fixing just compensation at ₱197,922.29. Diaz's motion for reconsideration was denied, leading her to file an ordinary appeal with the Court of Appeals. The Land Bank of the Philippines (Land Bank) and DAR failed to file their appellees' brief. Land Bank subsequently filed a motion to dismiss the appeal, arguing that an ordinary appeal was the incorrect remedy, and that a petition for review under Section 60 of Republic Act No. 6657 was the proper mode. The Court of Appeals denied Land Bank's motion to dismiss. 3. The Petition: Land Bank filed a petition for review on certiorari with the Supreme Court, arguing that the SAC decision had become final and executory due to Diaz's resort to the wrong mode of appeal. Land Bank contended that the Court of Appeals never acquired jurisdiction over the appeal. The Supreme Court granted the petition, holding that an ordinary appeal from SAC decisions is fatal, rendering the judgment final and executory, and thus setting aside the Court of Appeals' resolution and affirming the SAC decision.
Issue(s)
Whether the Court of Appeals acquired jurisdiction over the appeal filed by Elizabeth Diaz. Whether an ordinary appeal is the proper mode of appeal from decisions of Special Agrarian Courts.
Ruling
The petition is meritorious. The Resolution of the Court of Appeals dated June 21, 2009 is SET ASIDE. The Decision dated June 21, 2006 of the Regional Trial Court of Guimba, Nueva Ecija, Branch 33 sitting as a Special Agrarian Court in Agr. Case No. 1194-G is deemed final and executory.
Ratio Decidendi
On the issue of whether the Court of Appeals acquired jurisdiction over the appeal filed by Elizabeth Diaz: The Supreme Court held that the Court of Appeals did not acquire jurisdiction. Following the ruling in Land Bank of the Philippines v. De Leon, the proper mode of appeal from decisions of Regional Trial Courts sitting as Special Agrarian Courts (SACs) is a petition for review under Rule 42 of the Rules of Court, not an ordinary appeal under Rule 41. The Court clarified that Section 60 of Republic Act No. 6657 (Comprehensive Agrarian Reform Law) clearly and categorically states that a petition for review should be adopted. The Court emphasized that the failure to file the proper remedy within the reglementary period renders the decision final and executory. Therefore, Elizabeth's resort to an ordinary appeal was fatal to her cause, as it did not stop the running of the reglementary period to file a petition for review. The Court reiterated that the right to appeal is a statutory privilege, and its perfection in the manner and within the period prescribed by law is mandatory and jurisdictional. Failure to comply with these rules results in the judgment becoming final and executory, which can no longer be revised or altered by any court. On the issue of whether an ordinary appeal is the proper mode of appeal from decisions of Special Agrarian Courts: The Supreme Court definitively ruled that an ordinary appeal is not the proper mode. It explained that Section 60 of RA 6657 expressly regards a petition for review as the proper way of appealing decisions of agrarian courts. The Court further elaborated that there is no conflict between Sections 60 and 61 of RA 6657, and that the reference to the Rules of Court in Section 61 means that specific rules for petitions for review under Rule 42 and other relevant procedures shall be followed. The adoption of a petition for review is justified to hasten the resolution of cases involving just compensation, as prompt payment is essential for compensation to be considered "just." Unlike an ordinary appeal, a petition for review dispenses with the filing of a notice of appeal or completion of records before any pleading is submitted, thus expediting the award of fair recompense to landowners. The Court concluded that Elizabeth's failure to use the correct mode of appeal meant the SAC decision had attained finality.
Main Doctrine
Failure to file the proper mode of appeal within the reglementary period renders the decision final and executory, divesting the appellate court of jurisdiction.