Land Bank of the Philippines v. Suntay

G.R. No. 188376 (December 14, 2011)

Facts:

Federico Suntay owned a substantial tract of land in Sta. Lucia, Sablayan, Occidental Mindoro, totaling 3,682.0285 hectares. In 1972, a portion of his land, measuring 948.1911 hectares, was expropriated by the Department of Agrarian Reform (DAR) under Presidential Decree No. 27. The Land Bank of the Philippines (Land Bank) and the DAR initially valued the expropriated land at P4,497.50 per hectare, amounting to a total of P4,251,141.68. However, Suntay rejected this valuation and filed a petition for the determination of just compensation with the Regional Agrarian Reform Adjudicator (RARAD) of Region IV, which was assigned to RARAD Conchita MiAas.

On January 24, 2001, after a summary administrative proceeding, RARAD MiAas determined the just compensation for the expropriated land to be P157,541,951.30. Land Bank sought reconsideration, but this was denied. Subsequently, on April 20, 2001, Land Bank filed a petition for judicial determination of just compensation in the Regional Trial Court (RTC) of San Jose, Occidental Mindoro, seeking to have the compensation fixed at the original valuation of P4,251,141.67.

Despite the ongoing proceedings in the RTC, RARAD MiAas issued an order on May 22, 2001, declaring her earlier decision final and executory. Land Bank contested this order, leading to a series of legal maneuvers, including a petition for certiorari filed by Land Bank in the Court of Appeals (CA) to nullify RARAD MiAas's decisions.

The CA initially ruled in favor of Land Bank, but later reversed its decision, leading to further appeals and motions between the parties. The legal battle continued with various petitions and motions filed in both the RTC and the CA, culminating in a situation where the validity of RARAD MiAas's orders and the jurisdiction of the RTC as a Special Agrarian Court were heavily contested.

In 2008, RARAD MiAas issued an order to resume execution of the alias writ of execution, which led to the levying of Land Bank's shares in MERALCO and PLDT. This action was contested by Land Bank, which argued that the execution was improper and that the shares did not form part of the Agrarian Reform Fund (ARF) from which just compensation payments were to be made.

Legal Issues:

1. Whether the RTC had original and exclusive jurisdiction to determine just compensation under Republic Act No. 6657 (Comprehensive Agrarian Reform Law).
2. Whether the orders issued by RARAD MiAas and the subsequent actions taken by the DARAB sheriffs were valid and lawful.
3. Whether the CA erred in dismissing Land Bank's petition for certiorari on the grounds of mootness and academic nature.

Arguments:

• Land Bank's Position:

  • Land Bank argued that the RTC had original and exclusive jurisdiction over the determination of just compensation, as provided by Section 57 of R.A. No. 6657. It contended that the actions of RARAD MiAas and the DARAB were invalid as they attempted to usurp the RTC's jurisdiction.
  • Land Bank maintained that the execution of the writ against its shares was improper and that the shares did not belong to the ARF, thus should not be subject to levy for just compensation.

• Suntay's Position:

  • Suntay, represented by his assignee Josefina Lubrica, argued that the decision of RARAD MiAas had become final and executory due to Land Bank's failure to appeal within the prescribed period. He contended that the execution of the writ was valid and that the shares were subject to levy to satisfy the judgment.

Court's Decision and Legal Reasoning:

The Supreme Court ruled in favor of Land Bank, reversing the CA's decision that dismissed Land Bank's petition for certiorari. The Court emphasized that the RTC had original and exclusive jurisdiction over the determination of just compensation, and any attempt by the DARAB to assert jurisdiction over such matters was void. The Court clarified that the role of the DARAB was limited to preliminary determinations of compensation, leaving the final decision to the RTC.

The Court also found that the orders issued by RARAD MiAas to resume execution were invalid, as there was no valid prior order to resume. The execution against Land Bank's shares was deemed unlawful, as the shares did not form part of the ARF, and the proper procedure for execution was not followed.

The Court reiterated the principle that a judgment, once final, becomes immutable and unalterable, and that the actions taken by the DARAB sheriffs were in violation of the established rules governing the execution of judgments for just compensation.

Significant Legal Principles Established:

1. The original and exclusive jurisdiction to determine just compensation under R.A. No. 6657 lies with the RTC acting as a Special Agrarian Court.
2. The DARAB's role is limited to making preliminary determinations regarding compensation, and it cannot exercise original jurisdiction over just compensation cases.
3. A final judgment cannot be altered or modified, and any execution of such judgments must adhere strictly to the legal and procedural requirements set forth in relevant laws and rules.