Appeal, Review from RTC as Special Agrarian Court

AFC and HPI pray that the Decision and Resolution of the Court of Appeals in CA-G.R. SP No. 76222 be reversed and set aside and that the Decision of the RTC dated 25 September 2001 in Agrarian Cases No. 54-2000 and No. 55-2000 be declared as final and executory.

In the case of Land Bank of the Philippines v. De Leon, decided on 10 September 2002, respondents are the registered owners of a parcel of land. They voluntarily offered the subject property for sale to the government pursuant to Republic Act No. 6657. Unable to agree on the valuation of the property offered by the DAR, respondents filed a petition with the RTC (acting as a Special Agrarian Court) to fix the just compensation of the property. In due time, the RTC rendered judgment fixing the compensation of the property. Before the Court of Appeals, the DAR and LBP filed separate petitions. The DAR filed a Petition for Review of the decision of the RTC which was assigned to the Special 3rd Division of the appellate court. LBP, on the other hand, raised the case on appeal to the Court of Appeals by way of ordinary appeal. The same was assigned to the 4th Division of the Court of Appeals. The petition of the DAR was given due course. On the other hand, the Court of Appeals dismissed LBP’s ordinary appeal on the ground that the same was erroneous. LBP filed a petition for review before this Court. In Land Bank, we explained:
A petition for review, not an ordinary appeal, is the proper procedure in effecting an appeal from decisions of the Regional Trial Courts acting as Special Agrarian Courts in cases involving the determination of just compensation to the landowners concerned. Section 60 of RA 6657 clearly and categorically states that the said mode of appeal should be adopted. There is no room for a contrary interpretation. Where the law is clear and categorical, there is no room for construction, but only application.

LBP filed a Motion for Reconsideration. In a Resolution of this Court dated 20 March 2003, this Court emphasized the prospective application of the Decision dated 10 September 2002.

WHEREFORE, the motion for reconsideration dated October 16, 2002 and the supplement to the motion for reconsideration dated November 11, 2002 are PARTIALLY GRANTED. While we clarify that the Decision of this Court dated September 10, 2002 stands, our ruling therein that a petition for review is the correct mode of appeal from decisions of Special Agrarian Courts shall apply only to cases appealed after the finality of this Resolution.

Essentially therefore, the rule is that a decision of the RTC acting as a Special Agrarian Court should be brought to the Court of Appeals via a Petition for Review. The Court of Appeals will no longer entertain ordinary appeals thereon. However, this rule applies only after the finality of the Resolution of this Court in Land Bank of the Philippines v. De Leon dated 20 March 2003.

In this case, the Court of Appeals correctly ruled when it gave due course to the appeal of LBP. LBP’s Notice of Appeal was filed on 27 December 2001. This was given due course by the RTC in an Order dated 15 May 2002. LBP’s appeal was, thus, perfected before this Court’s Resolution in the aforementioned Land Bank of the Philippines v. De Leon case. Hence, the Court of Appeals could give due course to LBP’s petition. (G.R. No. 164195; December 19, 2007)