LANDBANK V. DE LEON (REMEDIAL)

The DAR and Landbank both filed separate appeals using different modes. DAR filed a petition for review while Landbank interposed an ordinary appeal by filing a notice of appeal.

The petition for review was given due course while the ordinary appeal was dismissed primarily holding that Landbank availed of the wrong mode of appeal.

In affirming the dismissal by the appellate court of Landbank's ordinary appeal, this Court held that in section 60 of RA 6657 (Comprehensive Agrarian Reform Law) is clear in providing petition for review as the appropriate mode of appeal from decision of the Special Agrarian Courts.

Section 61 (the provision on which Landbank bases its argument for review as the correct mode of appeal from decisions of Special Agrarian Courts) merely makes a general reference to the Rules of Court and does not categorically prescribe ordinary appeal as the correct way of questioning decisions of Special Agrarian Courts.

We ruled that the Rules of Court do not categorically prescribe ordinary appeal as the exclusive mode of appeal from decisions of Special Agrarian Courts. further, rules of procedure of special courts and quasi-judicial bodies shall remain effective unless disapproved by the SC.

On account of the absence of jurisprudence interpreting Sections 60 and 61 of RA 6657 regarding the proper way to appeal decisions of the Special Agrarian Courts, as well as the conflicting decisions of the CA thereon, Landbank cannot be blamed for availing of the wrong mode. Based on its own interpretation and reliance on the Buenaventura ruling, Landbank acted on the mistaken belief that an ordinary appeal is the appropriate manner to question decisions of Special Agrarian Courts.

We hold that our Decision, declaring a petition for review as the proper mode of appeal from judgments of Special Agrarian Courts, is a rule of procedure which affects substantive rights. If our ruling is given retroactive application, it will prejudice Landbank's right to appeal because pending appeals in the CA will be dismissed outright on mere technicality thereby sacrificing substantial merits thereof. It would be unjust to apply a new doctrine to a pending case involving a party who already invoked a contrary view and who acted in good faith thereon prior to the issuance of said doctrine.