Land Bank of the Philippines v. Herederos de Ciriaco Chunaco Destilleria

Summary

This case involves a dispute over the time limitation for filing petitions for determination of just compensation under the Comprehensive Agrarian Reform Program. Respondent corporation voluntarily offered 12 agricultural parcels for sale under CARP. After disagreeing with LBP's valuation of P957,991.30, PARAD valued the properties at P4,455,349.62. LBP filed a petition with the Special Agrarian Court allegedly beyond the 15-day DARAB Rules period. The Court of Appeals initially dismissed the case for being filed out of time. However, the Supreme Court reversed, applying its ruling in Land Bank v. Dalauta that the 15-day DARAB limitation has no statutory basis and that the 10-year prescriptive period under Civil Code Article 1144 applies instead. The case was remanded to the SAC for determination of just compensation. This decision clarifies the procedural requirements for just compensation cases and reinforces the original jurisdiction of Special Agrarian Courts in CARP proceedings.