Primary Holding
Decisions of trial courts designated as Special Agrarian Courts are appealable only to the Court of Appeals via a Rule 42 petition for review, without distinction as to whether the appeal raises questions of fact, questions of law, or mixed questions of fact and law.
Background
Petitioner-spouses Romeo and Rosielinda Plopenio owned 11.8643 hectares of coconut land in Caramoan, Camarines Sur, while their co-petitioner Eduardo Plopenio owned 22.8349 hectares in the same locality. In 2000, the DARAB valued the land of their brother Gavino Plopenio at ₱51,125.60 per hectare, prompting petitioners to offer their own landholdings to the DAR for acquisition and distribution under Republic Act No. 6657, the Comprehensive Agrarian Reform Law. The dispute arose from the valuation placed by Land Bank on petitioners' properties, which was significantly lower than the valuation previously assigned to their brother's land.
History
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PARAD, Camarines Sur, Sept. 5, 2002 — affirmed Land Bank's valuation of petitioners' properties; copy received by petitioners on Sept. 27, 2002.
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PARAD, Nov. 20, 2002 — denied petitioners' Motion for Reconsideration; copy received by petitioners on Dec. 21, 2002.
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SAC-RTC Branch 23, Naga City, Oct. 7, 2003 — dismissed petitioners' petitions for lack of valid cause of action, holding the PARAD Decision had attained finality due to late filing.
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SAC-RTC Branch 23, Naga City, Nov. 14, 2003 — denied petitioners' motions for reconsideration for lack of merit.
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Supreme Court, July 24, 2006 — resolved to consolidate G.R. Nos. 161090 and 161092 due to similarity in factual milieu and legal issues.
Facts
Petitioner-spouses Romeo and Rosielinda Plopenio owned 11.8643 hectares of coconut land in Caramoan, Camarines Sur, while petitioner Eduardo Plopenio owned 22.8349 hectares in the same locality. In 2000, the DARAB valued the land of their brother Gavino Plopenio at ₱51,125.60 per hectare in DARAB Case No. V-LV-040-CS-00. Taking this valuation as a benchmark, petitioners offered their entire landholdings to the DAR for acquisition and distribution under the Comprehensive Agrarian Reform Law.
On October 26, 2001, Land Bank sent a Notice of Valuation and Adjudication valuing the spouses' land at ₱23,485.00 per hectare and Eduardo's at ₱22,856.62 per hectare — figures substantially lower than the valuation given to their brother's property. Dissatisfied, petitioners rejected the notice and referred the matter to the Provincial Agrarian Reform Adjudicator (PARAD) of Camarines Sur for summary administrative proceedings. The PARAD affirmed Land Bank's valuation in a Decision dated September 5, 2002, a copy of which petitioners received on September 27, 2002.
Fourteen days later, on October 11, 2002, petitioners filed a Motion for Reconsideration with the PARAD. The PARAD denied the motion in an Order dated November 20, 2002, which petitioners received on December 21, 2002. Petitioners then filed separate petitions before the SAC-RTC on January 6, 2003 — sixteen days after receipt of the denial — reasoning that the 15-day period should be counted from receipt of the order denying their motion for reconsideration, and since the 15th day fell on a Sunday, they could file until January 6, 2003. Land Bank countered in its Answer that the PARAD Decision had already attained finality because the 15-day period should be counted from petitioners' receipt of the PARAD Decision itself.
The SAC-RTC ruled in favor of Land Bank, finding that the PARAD Decision had attained finality due to petitioners' failure to file on time, and dismissed the petitions for lack of valid cause of action. Petitioners' motions for reconsideration were denied. From these rulings, petitioners filed the instant Rule 45 petitions directly with the Supreme Court, which were consolidated on July 24, 2006.
Arguments of the Petitioners
- Pure Questions of Law: Petitioner argued that because the instant petitions raised only pure questions of law, the proper mode of appeal was via a Rule 45 petition directly to the Supreme Court, carving out an exception to the general rule requiring appeals from SACs to go to the Court of Appeals.
- Timeliness of Filing: Petitioner maintained that the 15-day period for filing the petition before the SAC-RTC should be reckoned from receipt of the order denying the motion for reconsideration, and since the 15th day fell on a Sunday, the filing on January 6, 2003 was timely.
Arguments of the Respondents
- Finality of PARAD Decision: Respondent Land Bank argued that the PARAD Decision had already attained finality after the lapse of the 15-day period counted from petitioners' receipt of the PARAD Decision, rendering the SAC-RTC petitions barred by prior final and executory judgment and wanting of a valid cause of action.
Issues
- Proper Mode of Appeal: Whether a Rule 45 petition directly to the Supreme Court is the proper mode of appeal from a decision of the RTC designated as a Special Agrarian Court when only pure questions of law are raised.
- Timeliness of SAC-RTC Petitions: Whether the petitions filed before the SAC-RTC were filed within the reglementary period under the 1994 DARAB Rules of Procedure.
Ruling
- Proper Mode of Appeal: No. The exclusive mode of appeal from decisions of the SAC-RTC is a Rule 42 petition for review to the Court of Appeals, regardless of whether the appeal raises questions of fact, questions of law, or mixed questions, pursuant to Section 60 of R.A. No. 6657.
- Timeliness of SAC-RTC Petitions: No. The petitions were filed out of time, petitioners having only one remaining day from the original 15-day period after their motion for reconsideration was denied, yet they filed sixteen days after receipt of the denial order.
Ruling Rationale
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Proper Mode of Appeal: Section 60 of the Comprehensive Agrarian Reform Law expressly provides that appeals from decisions of Special Agrarian Courts are taken to the Court of Appeals by filing a petition for review within fifteen days from receipt of notice. The statute makes no distinction between appeals raising questions of fact and those dealing purely with questions of law. Applying the maxim ubi lex non distinguit nec nos distinguere debemus, the Court declined to carve out an exception for pure questions of law. While the general rule under the Rules of Court permits appeals raising pure questions of law from RTC decisions to be taken directly to the Supreme Court via Rule 45, the special jurisdiction of the SAC-RTC is conferred and regulated by the Comprehensive Agrarian Reform Law, and appeals therefrom are governed exclusively by Section 60 thereof. The right to appeal being a remedy of statutory origin, it must be exercised only in the manner prescribed by the authorizing law. Consequently, the only proper mode is a Rule 42 petition to the Court of Appeals.
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Timeliness of SAC-RTC Petitions: Under the 1994 DARAB Rules, a party aggrieved by the adjudicator's decision on land valuation has 15 days to file an original petition before the SAC. The filing of a motion for reconsideration suspends the running of this period; upon receipt of the order denying the motion, the remaining balance of the period recommences. Although a petition for just compensation before the SAC-RTC is an original action rather than an appeal, the Court applied Section 12 of the 1994 DARAB Rules by analogy. Petitioners received the PARAD Decision on September 27, 2002, and filed their motion for reconsideration on October 11, 2002 — consuming 14 days of the 15-day period. Upon receiving the denial on December 21, 2002, only one day remained. Since December 22, 2002 fell on a Sunday, the deadline moved to December 23, 2002. Petitioners filed on January 6, 2003, sixteen days late. The petitions were thus filed out of time, and the PARAD Decision had attained finality.
Doctrines
- Statutory Right to Appeal — The right to appeal is a remedy of statutory origin and must be exercised only in the manner and in accordance with the provisions of the law authorizing its exercise. The Court applied this doctrine to hold that because Section 60 of R.A. No. 6657 expressly prescribes the Court of Appeals as the appellate forum for SAC decisions, that statutory mode is exclusive and cannot be circumvented by invoking the general Rule 45 procedure.
- Ubi Lex Non Distinguit — Where the law does not distinguish, neither should the courts. Section 60 of R.A. No. 6657 makes no distinction between questions of fact and questions of law in prescribing the mode of appeal from SAC decisions; accordingly, no such distinction was recognized.
- Suspension of Appeal Period by Motion for Reconsideration — Under Section 12 of the 1994 DARAB Rules, the filing of a motion for reconsideration suspends the running of the period to appeal. Upon denial, the movant has only the remainder of the original period to perfect the appeal. The Court applied this rule by analogy to the filing of an original petition for just compensation before the SAC-RTC.
Key Excerpts
- "Clearly, following the letter of the Comprehensive Agrarian Reform Law, petitioners should have appealed the SAC-RTC Decision to the Court of Appeals." — This passage underscores the Court's refusal to deviate from the express statutory text governing appeals from Special Agrarian Courts.
- "That law expressly states that appeals from SACs must be taken to the Court of Appeals without making a distinction between appeals raising questions of fact and those dealing purely with questions of law. Ubi lex non distinguit nec nos distinguere debemus. Where the law does not distinguish, neither should we." — This is the ratio decidendi on the mode-of-appeal issue, applying the statutory construction maxim to reject the pure-questions-of-law exception.
- "Consequently, we rule that the only mode of appeal from decisions of the SAC-RTC is via a Rule 42 petition for review to the Court of Appeals, without any distinction as to whether the appeal raises questions of fact, questions of law, or mixed questions of fact and law." — This is the canonical formulation of the rule established in this case, frequently cited in subsequent agrarian reform jurisprudence.
Precedents Cited
- Oro vs. Diaz, 413 Phil. 416 (2001) — Cited for the doctrine that the right to appeal is a remedy of statutory origin and must be exercised strictly in accordance with the law authorizing it.
- Land Bank of the Philippines vs. De Leon, 437 Phil. 347 (2002) — Cited for the proposition that the proper mode of appeal from SAC decisions is a Rule 42 petition for review to the Court of Appeals.
- Land Bank of the Philippines vs. Martinez, G.R. No. 169008, 31 July 2008, 560 SCRA 776 — Cited for the principle that a petition for the fixing of just compensation filed with the RTC-SAC is an original action before the court a quo, not an appeal from the PARAD's decision.
Provisions
- Section 60, Republic Act No. 6657 (Comprehensive Agrarian Reform Law) — Governs appeals from Special Agrarian Courts, providing that appeals from SAC decisions are taken to the Court of Appeals via petition for review within fifteen days from receipt of notice. Applied as the controlling statute to determine the exclusive mode of appeal, superseding the general Rule 45 procedure.
- Rule XIII, Section 11, 1994 DARAB Rules of Procedure — Provides that the decision of the adjudicator on land valuation and preliminary determination of just compensation shall be brought directly to the SAC within 15 days from receipt of notice, and that one motion for reconsideration is allowed.
- Rule VIII, Section 12, 1994 DARAB Rules of Procedure — Governs the effect of a motion for reconsideration on the appeal period, providing that filing suspends the running of the period and that upon denial, the movant has the remainder of the original period to perfect the appeal. Applied by analogy to the original petition for just compensation before the SAC-RTC.
Notable Concurring Opinions
Senior Associate Justice Antonio T. Carpio (Chairperson), Associate Justice Arturo D. Brion, Associate Justice Jose Portugal Perez, and Associate Justice Bienvenido L. Reyes concurred.