In a ruling that clarifies procedural requirements, the Supreme Court affirmed that appeals from decisions of Regional Trial Courts (RTCs) designated as Special Agrarian Courts (SACs) must be filed with the Court of Appeals (CA), regardless of whether the appeal raises questions of fact, law, or mixed questions. This decision underscores the importance of adhering to the specific modes of appeal prescribed by law and ensures uniformity in the application of agrarian reform legislation. The failure to follow the correct procedure can lead to the dismissal of an appeal, as demonstrated in this case.

Agrarian Dispute or Procedural Misstep? Unraveling the Plopenio Appeal

This case revolves around the land valuation dispute between the Spouses Romeo and Rosielinda Plopenio, along with Eduardo Ll. Plopenio, and the Department of Agrarian Reform (DAR) and Land Bank of the Philippines (LBP). Dissatisfied with the LBP’s valuation of their landholdings for acquisition under the Comprehensive Agrarian Reform Law (CARL), the Plopenios sought a higher valuation, leading to a legal battle that ultimately hinged on the proper procedure for appealing decisions from the Special Agrarian Court (SAC). The central legal question is whether an appeal from a SAC decision should be filed directly with the Supreme Court if it involves only questions of law, or with the Court of Appeals, as mandated by Section 60 of the CARL.

The heart of the matter lies in Section 60 of the Comprehensive Agrarian Reform Law, which explicitly states:

Section 60. Appeals. – An appeal may be taken from the decision of the Special Agrarian Courts by filing a petition for review with the Court of Appeals within fifteen (15) days from receipt of notice of the decision; otherwise, the decision shall become final.

An appeal from the decision of the Court of Appeals, or from any order, ruling or decision of the DAR, as the case may be, shall be by a petition for review with the Supreme Court within a non-extendible period of fifteen (15) days from receipt of a copy of said decision.

This provision is unambiguous: appeals from SAC decisions must be taken to the Court of Appeals. The petitioners, however, argued that because their petitions raised only pure questions of law, the proper venue for appeal was directly with the Supreme Court. This argument was based on the general rule that appeals raising pure questions of law from decisions of RTCs are taken to the Supreme Court via a Rule 45 petition.

The Supreme Court rejected this argument, emphasizing that the right to appeal is statutory and must be exercised in accordance with the law authorizing it. The Court underscored the principle of statutory construction: *Ubi lex non distinguit nec nos distinguere debemus* – where the law does not distinguish, neither should we. This means that because Section 60 of the CARL does not differentiate between appeals raising questions of fact and those dealing purely with questions of law, no such distinction should be made.

We have repeatedly ruled that the right to appeal is a remedy of statutory origin. As such, this right must be exercised only in the manner and in accordance with the provisions of the law authorizing its exercise. The special jurisdiction of the SAC-RTC is conferred and regulated by the Comprehensive Agrarian Reform Law, and appeals therefrom are governed by Section 60 thereof. 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. 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.

Beyond the procedural misstep, the Court also addressed the timeliness of the petitions filed before the SAC-RTC. Under the 1994 DARAB Rules of Procedure, which were in effect at the time, a decision of the adjudicator on land valuation must be brought directly to the SAC within 15 days from receipt of the notice. The filing of a motion for reconsideration suspends this period, but upon denial of the motion, the period resumes. In this case, the petitioners filed their petitions with the SAC-RTC beyond the prescribed period.

Key Issue	The correct mode of appeal from decisions of the Special Agrarian Courts (SAC).
What was the Court’s Ruling?	Appeals from SAC decisions must be filed with the Court of Appeals, regardless of the nature of the questions raised.
What is Section 60 of CARL?	It mandates that appeals from SAC decisions should be filed with the Court of Appeals within 15 days of notice.
What happens if the appeal is filed in the wrong court?	The appeal can be dismissed due to procedural errors.
What is the principle of *Ubi lex non distinguit nec nos distinguere debemus*?	It means that where the law does not distinguish, neither should the courts.
Can a motion for reconsideration extend the appeal period?	Yes, but only temporarily. The period resumes upon the denial of the motion.
What were the 1994 DARAB Rules of Procedure?	They governed the timeline for appealing decisions on land valuation during the case proceedings.
Is the 15-day appeal period extendable?	No, as stated in Section 60 of the CARL, the period is non-extendible.

This case serves as a critical reminder of the importance of adhering to procedural rules in legal proceedings, particularly in agrarian disputes. The Supreme Court’s decision emphasizes that failing to follow the prescribed mode of appeal can be fatal to a case, regardless of the merits of the substantive issues involved. Strict compliance with statutory requirements is essential to ensure the proper and efficient administration of justice.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Spouses Romeo Ll. Plopenio and Rosielinda Plopenio vs. Department of Agrarian Reform and Land Bank of the Philippines, G.R. No. 161090 and G.R. No. 161092, July 04, 2012