Landbank vs Martinez GR 169008, Aug. 14, 2007 530 SCRA 158

Fact: After compulsory acquisition by the DAR, respondent’s land pursuant to Republic Act No. 6657 or the CARL, petitioner LBP offered ₱1,955,485.60 as just compensation. Convinced that the proffered amount was unjust and confiscatory, respondent rejected it. Thus, the Department of Agrarian Reform Adjudication Board (DARAB), through its Provincial Agrarian Reform Adjudicator (PARAD) conducted summary administrative proceedings for the preliminary determination of just compensation in accordance with Section 16 (d) of the CARL. On September 4, 2002, PARAD Virgilio M. Sorita, finding some marked inconsistencies in the figures and factors made as bases by LBP in its computation, rendered judgment to pay respondent the total amount of Php12,179,492.50. A petition for the fixing of just compensation was then filed by LBP before the Special Agrarian Court (SAC), the RTC After filing her answer to the said petition, respondent, contending that the orders, rulings and decisions of the DARAB become final after the lapse of 15 days from their receipt, moved for the dismissal of the petition for being filed out of time. Petitioner opposed the motion.

Issue: Whether the Suntay Doctrine reglamentary period on appeal in the determination of Just compensation should followed.

Held: No, To resolve the conflict in the rulings of the Court, the court declared herein, for the guidance of the bench and the bar, that the better rule is that stated in Philippine Veterans Bank, reiterated in Lubrica and in the August 14, 2007 Decision in this case. Thus, while a petition for the fixing of just compensation with the SAC is not an appeal from the agrarian reform adjudicator’s decision but an original action, the same has to be filed within the 15-day period stated in the DARAB Rules; otherwise, the adjudicator’s decision will attain finality. This rule is not only in accord with law and settled jurisprudence but also with the principles of justice and equity. the Court reiterates its ruling in this case that the agrarian reform adjudicator’s decision on land valuation attains finality after the lapse of the 15-day period stated in the DARAB Rules. The petition for the fixing of just compensation should therefore, following the law and settled jurisprudence, be filed with the SAC within the said period. This conclusion, as already explained in the assailed decision, is based on the doctrines laid down in Philippine Veterans Bank v. Court of Appeals and Department of Agrarian Reform Adjudication Board v. Lubrica. The Court ruled that the trial court correctly dismissed the petition for the fixing of just compensation because it was filed beyond the 15-day period provided in the DARAB Rules. That the adjudicator’s decision had already attained finality because LBP filed the petition for just compensation beyond the 15-day reglementary period.

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