Plopenio v. Department of Agrarian Reform
REITERATIONFacts
The Antecedents: Petitioners Spouses Romeo and Rosielinda Plopenio own 11.8643 hectares of coconut land, and petitioner Eduardo Ll. Plopenio owns 22.8349 hectares of coconut land in Caramoan, Camarines Sur. Based on a prior valuation of a neighboring property, the petitioners offered their landholdings to the Department of Agrarian Reform (DAR) for acquisition and distribution under the Comprehensive Agrarian Reform Law. The Land Bank of the Philippines subsequently issued Notices of Valuation and Adjudication, valuing the petitioners' lands at P23,485.00 per hectare for the spouses and P22,856.62 per hectare for Eduardo. Dissatisfied with these valuations, the petitioners rejected the offers and sought administrative proceedings before the Provincial Agrarian Reform Adjudicator (PARAD). Procedural History: The PARAD affirmed the Land Bank's valuations in a Decision dated September 5, 2002. The petitioners received this decision on September 27, 2002, and filed a Motion for Reconsideration on October 11, 2002, fourteen days later. The PARAD denied this motion in an Order dated November 20, 2002, which the petitioners received on December 21, 2002. Sixteen days after receiving the denial, on January 6, 2003, the petitioners filed separate Petitions before the Special Agrarian Court (SAC) of the Regional Trial Court (RTC). The Land Bank argued that the PARAD's decision had become final due to the late filing of the petitions before the SAC. The SAC-RTC agreed, dismissing the petitions for lack of valid cause of action, and subsequently denied the petitioners' motions for reconsideration. The Petition: Petitioners filed these consolidated Rule 45 Petitions directly with the Supreme Court, assailing the Decisions and Orders of the SAC-RTC. They contend that their appeals to the SAC-RTC were timely filed, arguing that the 15-day period for filing should be extended because the 15th day fell on a Sunday. Furthermore, they argue that because their petitions raise pure questions of law, a direct appeal via Rule 45 to the Supreme Court is the proper mode, bypassing the Court of Appeals as mandated by Section 60 of the Comprehensive Agrarian Reform Law. The Supreme Court, however, addresses the procedural issue of the correct mode of appeal and the timeliness of the filings before the SAC-RTC.
Issue(s)
Whether the mode of appeal from a Special Agrarian Court (SAC) decision to the Supreme Court is via a Rule 45 Petition for Review. Whether the Petitions filed before the SAC-RTC were filed within the reglementary period.
Ruling
The Supreme Court denied the consolidated Petitions. It ruled that the mode of appeal from a SAC decision is exclusively to the Court of Appeals via a Rule 42 petition for review. Furthermore, the Court found that the petitions before the SAC-RTC were filed out of time.
Ratio Decidendi
On the Mode of Appeal: The Court reiterated that Section 60 of the Comprehensive Agrarian Reform Law (R.A. 6657) explicitly provides that appeals from Special Agrarian Courts shall be taken to the Court of Appeals within fifteen (15) days from receipt of notice of the decision. This rule applies regardless of whether the appeal involves questions of fact, questions of law, or mixed questions. The Court emphasized that the right to appeal is statutory and must be exercised in the manner prescribed by law. Therefore, filing a Rule 45 Petition directly with the Supreme Court from a SAC decision is a wrongful mode of appeal. The Court stated, "Where the law does not distinguish, neither should we." The proper procedure, as mandated by law and jurisprudence, is to first appeal to the Court of Appeals. On the Timeliness of the Petition before the SAC-RTC: The Court found that the petitions before the SAC-RTC were filed out of time. Under the 1994 DARAB Rules of Procedure, a motion for reconsideration suspends the running of the period to appeal. Petitioners received the PARAD's Decision on September 27, 2002. They filed a motion for reconsideration on October 11, 2002, thus suspending the reglementary period. They received the Order denying their motion on December 21, 2002. This meant they had one day remaining to file their petition with the SAC-RTC. Since December 22, 2002, was a Sunday, they should have filed by December 23, 2002. However, they filed on January 6, 2003, which was 16 days after receiving the denial order, clearly beyond the allowed period. The Court noted that while a petition before the SAC-RTC is an original action, the rule on suspension of the reglementary period by a motion for reconsideration finds analogous application.
Main Doctrine
Decisions of Special Agrarian Courts (SACs) are only appealable to the Court of Appeals via a Rule 42 petition for review, regardless of whether the appeal raises questions of fact, questions of law, or mixed questions of fact and law. Filing a Rule 45 petition directly with the Supreme Court from a SAC decision is a wrongful mode of appeal.