Puyat & Sons v. Alcalde
REVERSALFacts
1. The Antecedents: The underlying dispute concerns the potential coverage of a 37.7353-hectare portion of land owned by Gonzalo Puyat & Sons, Inc. (petitioner) under the Comprehensive Agrarian Reform Program (CARP). The Municipal Agrarian Reform Officer (MARO) issued a Notice of Coverage in April 1998, followed by a Notice of Valuation and Acquisition in November 1998, offering P7,071,988.80 as compensation. Petitioner argued that the land was purchased in good faith, remained uncultivated and untenanted, and was classified as industrial, thus exempt from CARP. Respondents countered that the industrial classification was recent, the municipality lacked an approved zoning ordinance, they were not beneficiaries who executed waivers, and the land was planted with palay. 2. Procedural History: The Department of Agrarian Reform (DAR) Secretary, on June 8, 2001, issued an order dismissing petitioner's plea and declaring the land as agricultural, subject to CARP. An Order of Finality was issued on August 6, 2001, after petitioner's motion to lift the finality was denied. Petitioner appealed to the Office of the President (OP), which, on August 8, 2003, set aside the DAR orders and lifted the notices of coverage and acquisition. The OP later dismissed a Petition for Relief filed by respondents. Respondents then appealed to the Court of Appeals (CA), which, on February 1, 2005, granted the petition, set aside the OP's decision, and reinstated the DAR Secretary's orders. This Court, in a February 1, 2012 decision, reversed the CA, reinstating the OP's decision. The present resolution stems from respondents' Motion for Reconsideration of this Court's 2012 decision. 3. The Petition: Respondents filed a Motion for Reconsideration and a Supplement, urging this Court to reconsider its February 1, 2012 decision. They argue that the Court erred in ruling that the DAR's June 8, 2001 Order had not become final and executory, and that the MARO failed to comply with pre-ocular inspection requirements. The core issues presented are whether the DAR's June 8, 2001 Order had attained finality, and whether the MARO's actions constituted compliance with procedural due process, specifically regarding the ocular inspection and land classification, which would determine the land's suitability for CARP coverage.
Issue(s)
Whether the June 8, 2001 Order of the DAR has become final and executory. Whether the MARO failed to comply with the pre-ocular inspection requirements of DAR Administrative Order No. 01, Series of 1998.
Ruling
The Court granted the respondents' Motion for Reconsideration, set aside its February 1, 2012 Decision, and reinstated the Court of Appeals' February 1, 2005 Decision and April 25, 2005 Resolution, thereby reinstating the Orders dated June 8, 2001 and November 5, 2001 of the Department of Agrarian Reform Secretary.
Ratio Decidendi
On the finality of the June 8, 2001 Order: The Court found that the June 8, 2001 Order of the DAR had already attained finality. Petitioner's motion for reconsideration was filed on September 14, 2001, which was beyond the 15-day reglementary period, even assuming the counsel's admission of receipt on August 17, 2001, which would have made the deadline September 1, 2001. Furthermore, the DAR's August 3, 2001 Order deemed the June 8, 2001 Order served upon petitioner due to the counsel's failure to notify the DAR of his change of address, constituting inexcusable neglect binding upon the client. The Court reiterated that clients are bound by the actions of their counsel, and failure to inform the court of a change of address is an inexcusable omission. Additionally, petitioner's filing of a Motion to Lift Order of Finality on August 20, 2001, quoting the dispositive portion of the June 8, 2001 Order, demonstrated actual knowledge of the order, which is equivalent to notice. This actual knowledge meant petitioner had until September 4, 2001, at the latest, to file a motion for reconsideration, making the September 14, 2001 filing untimely. Once a decision becomes final and executory, it can no longer be disturbed, as it becomes the law of the case. On the MARO's compliance with pre-ocular inspection requirements: The Court found that the conclusion that no preliminary ocular inspection was conducted was flawed. The existence of CARP Form No. 3.a, the "Preliminary Ocular Inspection Report," signed by the inspectors and attested by the MARO, belied this conclusion. The presumption of regularity in the performance of official duty applied, and the failure to mark specific checkboxes for "Land Use" or "Land Condition/Suitability to Agriculture" did not negate the fact that an inspection was conducted or that the land was agricultural. The Court noted that the sub-categories under "Land Condition/Suitability to Agriculture" and "Land Use" did not negate the finding that the landholding was agricultural. Moreover, a Memorandum dated March 3, 2005, from the Provincial Agrarian Reform Officer (PARO) confirmed that an ocular inspection had been conducted and the landholdings were indeed agricultural in nature, citing surrounding areas planted with palay. The Court also found that petitioner failed to present evidence of a valid reclassification from agricultural to industrial land. The reclassification by the Sangguniang Bayan of Biñan was not approved by the Housing and Land Use Regulatory Board (HLURB) as of October 16, 1997, and the tax declaration merely indicated a "proposed industrial" area, not a definitive reclassification. Furthermore, any conversion or reclassification requires authorization from the DAR under Section 65 of Republic Act No. 6657, which was not shown to have been obtained.
Main Doctrine
A motion for reconsideration filed beyond the reglementary period, especially when the order sought to be reconsidered has already attained finality, cannot be given due course. Failure to notify the DAR of a change of counsel's address constitutes inexcusable neglect binding upon the client, and actual knowledge of an order is equivalent to notice.