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Case Digest: Limkaichong vs Land Bank of the Philippines799 SCRA 139G.R. No. 158464, August 02, 2016
Limkaichong vs. Land Bank of the Philippines
799 SCRA 139
G.R. No. 158464
August 02, 2016
Petitioner Jocelyn Limkaichong was the registered owner of agricultural lands with a total area of 19.6843 hectares situated in Villegas, Guihulngan, Negros Oriental placed under CARP coverage.
On May 28, 1999, the DARAB issued its order affirming the valuation of the lands upon finding the valuation earlier rejected by petitioner as consistent with existing administrative guidelines on land valuation.
On August 19, 1999, the petitioner filed in the RTC in Dumaguete City a complaint for the fixing of just compensation for her lands.
On June 7, 2001, the RTC as the SAC granted the respondents' motion to dismiss. Citing Section 51 and Section 5416 of R.A. No. 6657 and Section 11 of Rule XIII of the 1994 DARAB Rules of Procedure, it held that the petitioner's complaint should have been filed within 15 days from notice of the assailed order. It dismissed her argument that the case was anchored on violations of her constitutional rights to due process and just compensation, declaring that the controlling ruling was Philippine Veterans Bank v. Court of Appeals, not Republic v. Court of Appeals. Thus, applying the ruling in Philippine Veterans Bank, the RTC concluded that dismissal was proper because she had filed Civil Case No. 12558 beyond the statutory 15-day period.
Court of Appeals affirmed the RTC decision.
Whether or not the trial court's dismissal of her petition because of her failure to file it before the decision/order of the DARAB became final and executory pursuant to Section 51 of R.A, No. 6657 was fair and proper.
No. We cannot fairly and properly hold that the petitioner's complaint for the determination of just compensation should be barred from being tried and decided on that basis. The prevailing rule at the time she filed her complaint on August 19, 1999 was that enunciated in Republic v. Court of Appeals on October 30, 1996. The pronouncement in Philippine Veterans Bank was promulgated on January 18, 2000 when the trial was already in progress in the RTC, At any rate, it would only be eight years afterwards that the Court en banc unanimously resolved the jurisprudential conundrum through its declaration in Land Bank v. Martinez that the better rule was that enunciated in Philippine Veterans Bank, The Court must, therefore, prospectively apply Philippine Veterans Bank. The effect is that the petitioner's cause of action for the proper valuation of her expropriated property should be allowed to proceed. Hence, her complaint to recover just compensation was properly brought in the RTC as the SAC, whose dismissal of it upon the motion of Land Bank should be undone.