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

Fact: After compulsory acquisition by the Department of Agrarian Reform (DAR), on respondent land pursuant to the Comprehensive Agrarian Reform Law of 1988 (CARL), petitioner offered ₱1,955,485.60 as just compensation. 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 the CARL. PARAD, finding some marked inconsistencies in the figures and factors made as bases by LBP in its computation, rendered judgment and determined the just compensation to Php12,179,492.50.

A petition for the fixing of just compensation was then filed by LBP’s counsel 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. Meanwhile, respondent, filed before the Office of the PARAD a motion for the issuance of a writ of execution, which was eventually granted. Hence this petition.

Issue: Whether a petition for the fixing of just compensation with the SAC though an original action must still be filed within the reglamentary period of 15 days after the decision of the DARAB.

Held: Yes, To resolve the conflict in the rulings of the Court, it now declare herein 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. Verily, a belated petition before the SAC, e.g., one filed a month, or a year, or even a decade after the land valuation of the DAR adjudicator, must not leave the dispossessed landowner in a state of uncertainty as to the true value of his property.