Land Bank v. Herederos De Ciriaco Chunaco Distileria
REITERATIONFacts
The Antecedents: Respondent Herederos De Ciriaco Chunaco Distileria, Inc. owned several parcels of land totaling 22.587 hectares. In November 2001, the respondent voluntarily offered these lands for sale to the Republic of the Philippines under the Comprehensive Agrarian Reform Program (CARP). The petitioner, Land Bank of the Philippines (LBP), determined the CARP compensation to be P957,991.30. The respondent rejected this valuation, asserting the lands were worth P195,410.07 per hectare. Procedural History: Twelve cases for preliminary administrative determination of just compensation were initiated before the Provincial Agrarian Reform Adjudicator (PARAD) of Albay. The PARAD, in a decision dated February 17, 2004, ruled in favor of the respondent, setting the just compensation at P4,455,349.00. The LBP's motion for reconsideration was denied by the PARAD on April 1, 2004. Subsequently, the LBP filed a petition for judicial determination of just compensation before the Regional Trial Court (RTC), acting as a Special Agrarian Court (SAC), on April 12, 2004. The PARAD issued an order declaring its decision final and executory and a writ of execution on July 27, 2004, and September 10, 2004, respectively. The LBP then filed a petition for certiorari with the Department of Agrarian Reform Adjudication Board (DARAB), which denied the petition for lack of merit on July 7, 2005, and subsequently denied the motion for reconsideration on December 19, 2006. The Court of Appeals (CA) affirmed the DARAB's decision on April 26, 2013, holding that the LBP's petition before the RTC-SAC was filed out of time. The Petition: This case is an appeal by certiorari filed by the Land Bank of the Philippines seeking to reverse the CA's decision. The petitioner argues that it had a fresh fifteen (15)-day period to file its petition for judicial determination of just compensation before the RTC-SAC after its motion for reconsideration was denied by the PARAD. The petitioner contends that the RTC-SAC has original and exclusive jurisdiction over such matters and that the PARAD lost jurisdiction upon the filing of the petition before the RTC-SAC, thus preventing the PARAD from enforcing its decision. The core issue is whether a fresh fifteen (15)-day period is available to commence an action in the SAC after the denial of a motion for reconsideration of the PARAD's decision.
Issue(s)
Whether a fresh fifteen (15)-day period is available to commence an action in the Special Agrarian Court (SAC) after denial of a motion for reconsideration of the decision of the Agrarian Reform Adjudicator under the CARP Law (R.A. 6657, as amended). Whether the petition for judicial determination of just compensation was timely filed before the RTC-SAC. Whether the PARAD can enforce its decision while a petition for judicial determination of just compensation is pending before the RTC-SAC.
Ruling
The Supreme Court granted the petition, reversed the Court of Appeals' decision, and set aside the DARAB's resolutions. The Court ruled that the PARAD shall not enforce its February 17, 2004 Decision until after the finality of the judicial determination of just compensation.
Ratio Decidendi
On the applicability of the fresh 15-day period under Neypes v. Court of Appeals: The Court found it immaterial to determine whether a fresh 15-day period should be given after the denial of a motion for reconsideration, given that the 15-day period under the DARAB Rules itself was set aside. The correct period to file a petition for judicial determination of just compensation before the RTC-SAC is ten (10) years pursuant to Article 1144(2) of the Civil Code. The Court clarified that the Neypes ruling, which grants a fresh 15-day period after the denial of a motion for reconsideration, applies to judicial proceedings and not to administrative ones, as previously held in Pajolino v. Tajala. However, this distinction became moot with the abandonment of the 15-day DARAB rule. On the timeliness of the petition for judicial determination of just compensation: The Court held that the petition for judicial determination of just compensation was timely filed. It reiterated that the determination of just compensation is an essentially judicial function vested with the Special Agrarian Courts (SACs) under Section 57 of R.A. No. 6657, granting them original and exclusive jurisdiction. The Court explicitly abandoned its previous rulings in Veterans Bank, Martinez, and Soriano that a petition for determination of just compensation before the SAC must be filed within the 15-day period prescribed under the DARAB Rules. Such rulings were deemed incompatible with the legislative intent to vest original and exclusive jurisdiction with the SACs, as the DAR has no authority to qualify or undo this power. The Court emphasized that any DAR regulation attempting to reduce the SAC's original jurisdiction to an appellate one within a short period is void. The Court further clarified that while R.A. No. 6657 does not provide a specific period, the Civil Code settles this conundrum. Considering that the payment of just compensation is an obligation created by law, the prescriptive period should be ten (10) years from the time the landowner receives notice of coverage, pursuant to Article 1144(2) of the Civil Code. Any interruption or delay caused by the government, such as proceedings in the DAR, should toll the running of this prescriptive period. In this case, the respondent voluntarily offered its lands in November 2001, and the petition was filed on April 12, 2004, which was well within the 10-year period and was further tolled by the PARAD proceedings. Therefore, the 15-day reglementary period under Section 11, Rule XIII of the DARAB Rules cannot be sustained. On the enforcement of the PARAD decision: The Court ruled that the PARAD cannot enforce its February 17, 2004 decision because there is still a pending judicial determination of just compensation before the courts. The Court cited Dalauta stating that a landowner should withdraw their case with the DAR before filing with the RTC-SAC. In this case, petitioner did not appeal to the DARAB after the PARAD denied its motion for reconsideration but instead filed a petition before the RTC-SAC. The administrative proceedings were thus terminated. It was only when the PARAD ordered the execution of its decision, despite the pending judicial determination, that petitioner sought refuge from the DARAB. The cause of action was to stop the enforcement of the PARAD decision due to the pending petition before the RTC-SAC. The award of just compensation may only be executed after the judicial determination attains finality.
Main Doctrine
The 15-day reglementary period under Section 11, Rule XIII of the DARAB Rules for filing a petition for judicial determination of just compensation before the RTC-SAC is set aside as it undermines the original and exclusive jurisdiction of the RTC-SAC under Section 57 of R.A. No. 6657. The proper prescriptive period is ten (10) years pursuant to Article 1144(2) of the Civil Code, from the time the landowner receives notice of coverage, subject to tolling by government proceedings.