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LAND BANK OF PHILIPPINES v. RAYMUNDA MARTINEZ

This case has been cited 3 times or more.

2012-07-04
SERENO, J.
While a petition for the fixing of just compensation filed with the RTC-SAC is not an appeal from the PARAD's decision, but an original action before the court a quo,[22] the rule in Section 12 of the 1994 DARAB Rules should find analogous application. A party aggrieved by the PARAD's decision is given 15 days to file the original petition before the SAC-RTC. The pendency of a motion for reconsideration of the decision suspends the running of the period within which the petition may be filed before the RTC-SAC. Consequently, upon receipt of the order denying the motion for reconsideration, the reglementary period for filing the petition before the RTC-SAC again commences to run.
2011-12-14
BERSAMIN, J.
The controversy is traceable to the October 30, 2005 Order of RARAD MiƱas directing the DARAB sheriffs to resume the implementation of the alias writ of execution she had issued in DARAB Case No. V-0405-0001-00. She predicated her order on the following pronouncement made in Land Bank v. Martinez,[76] viz: To resolve the conflict in the rulings of the Court, we now declare herein, for the guidance of the bench and the bar, that the better rule is that stated in Philippine Veterans Bank, reiterated in Lubrica and in the August 14, 2007 Decision in this case. Thus, while a petition for the fixing of just compensation with the SAC is not an appeal from the agrarian reform adjudicator's decision but an original action, the same has to be filed within the 15-day period stated in the DARAB Rules; otherwise, the adjudicator's decision will attain finality. This rule is not only in accord with law and settled jurisprudence but also with the principles of justice and equity. Verily, a belated petition before the SAC, e.g., one filed a month, or a year, or even a decade after the land valuation of the DAR adjudicator, must not leave the dispossessed landowner in a state of uncertainty as to the true value of his property.[77]
2011-07-27
VILLARAMA, JR., J.
To foreclose any uncertainty brought by the Suntay ruling, this Court in its July 31, 2008 Resolution denying LBP's motion for reconsideration of the August 14, 2007 Decision in the case of Land Bank of the Philippines v. Martinez[28] held: On the supposedly conflicting pronouncements in the cited decisions, the Court reiterates its ruling in this case that the agrarian reform adjudicator's decision on land valuation attains finality after the lapse of the 15-day period stated in the DARAB Rules. The petition for the fixing of just compensation should therefore, following the law and settled jurisprudence, be filed with the SAC within the said period. This conclusion, as already explained in the assailed decision, is based on the doctrines laid down in Philippine Veterans Bank v. Court of Appeals and Department of Agrarian Reform Adjudication Board v. Lubrica.