Landbank vs De Leon GR 143275, Dec. 29, 1999 321 SCRA 629

Fact: Respondents filed a petition to fix the just compensation of a parcel of land before the RTCof Tarlac acting as a Special Agrarian Court. The agrarian court rendered summary judgment fixing the compensation of the subject property. The DAR and LBP both filed separate appeals using different modes. DAR filed a petition for review while LBP interposed an ordinary appeal by filing a notice of appeal. DAR’s petition for review was given due course and partially reconsidered and ordered to recompute the compensation. Petitioner is ordered to pay legal interest at 6% of the compensation so fixed from 1990 until full payment is made by the government. Meanwhile, the appellate court dismissed LBP’s ordinary appeal primarily holding that LBP availed of the wrong mode of appeal. LBP filed a motion for reconsideration but the same was denied. LBP filed before this Court a petition for review of the decision of the Court of Appeals which affirms the assailed resolution. Hence, LBP filed the instant motion for reconsideration and supplement to the motion for reconsideration reiterating its claim in the petition for review that Section 60 of RA 6657 is unconstitutional. LBP still maintains that a legislative act like Section 60 infringes on the exclusive rule-making power of this Court in violation of the 1987 Philippine Constitution. That in the event that said argument is again rejected, LBP pleads that the subject Decision should at least be given prospective application considering that more than 60 similar agrarian cases filed by LBP via ordinary appeal before the Court of Appeals are in danger of being dismissed outright on technical grounds on account of our ruling herein. This, according to LBP, will wreak financial havoc not only on LBP as the financial intermediary of the Comprehensive Agrarian Reform Program but also on the national treasury and the already depressed economic condition of our country. Thus, in the interest of fair play, equity and justice, LBP stresses the need for the rules to be relaxed so as to give substantial consideration to the appealed cases.

Issue: Whether an ordinary appeal is the proper way to appeal decisions of Special Agrarian Courts

Held: No, the court ruled that a petition for review is the correct mode of appeal from decisions of Special Agrarian Courts. the court recognized that LBP had no authoritative guideline on how to appeal decisions of Special Agrarian Courts considering the seemingly conflicting provisions of Section 60 and 61 of RA 6657. More importantly, acknowledges that the Court of Appeals has rendered conflicting decisions on this precise issue. On account of the absence of jurisprudence as well as the conflicting decisions of the Court of Appeals, LBP cannot be blamed for availing of the wrong mode. Hence, the court finds it proper to emphasize the prospective application of our Decision dated September 10, 2002. A prospective application of our Decision is not only grounded on equity and fair play but also based on the constitutional tenet that rules of procedure shall not impair substantive rights. In accordance with our constitutional power to review rules of procedure of special courts. The court declared that a petition for review as the proper mode of appeal from judgments of Special Agrarian Courts, is a rule of procedure which affects substantive rights. If the ruling is given retroactive application, it will prejudice LBP’s right to appeal because pending appeals in the Court of Appeals will be dismissed outright on mere technicality thereby sacrificing the substantial merits thereof. It would be unjust to apply a new doctrine to a pending case involving a party who already invoked a contrary view and who acted in good faith thereon prior to the issuance of said doctrine. The said doctrine shall apply only to cases appealed after the finality of this Resolution.

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