First, there is no conflict between Section[s] 60 and 61 of RA 6657 inasmuch as the Rules of Court do not at all prescribe the procedure for ordinary appeals as the proper mode of appeal for decisions of Special Agrarian Courts. Section 61 in fact makes no more than a general reference to the Rules of Court and does not even mention the procedure for ordinary appeals in Section 2, Rule 41 of the 1997 Revised Rules of Civil Procedure as the appropriate method of elevating to the Court of Appeals decisions of Special method of elevating to the Court of Appeals decisions of Special Agrarian Courts in eminent domain cases.
Second, the failure to mention Special Agrarian Courts in Section 1 of Rule 43 of the Revised Rules of Civil Procedure cannot be construed to mean that a petition for review is not permissible for decisions of the said special courts. In fact, the said Rule is not relevant to determine whether a petition for review is the proper mode of appeal from decisions of Regional Trial Courts in agrarian cases, that is, why they act as Special Agrarian Courts. Section 1 of Rule 43 of the 1997 Revised Rules of Civil Procedure merely mentions the Court of Tax Appeals and the other different quasi-judicial agencies without exclusivity in its phraseology. Such omission cannot be construed to justify the contention that a petition for review is prohibited for decisions on special agrarian cases inasmuch as the category is for quasi-judicial agencies and tax courts to which the Regional Trial Courts do not properly belong. Although Supreme Court of Circular No. 1-91 (precursor to Rule 43 of the Revised Rules of Civil Procedure) included the decisions of Special Agrarian Courts in the enumeration requiring petition for review, its non-inclusion later on in Rule 43 merely signifies that it was inappropriately classified as a quasi-judicial agencies.
What is indisputable is that Section 60 expressly regards a petition for review as the proper way of appealing decisions of agrarian courts. So far, there is no rule prescribed by this Court expressly disallowing the said procedure.
Third, far from being in conflict, Section 61 of RA 6657 can easily be harmonized with Section 60. The reference to the Rules of Court means that the specific rules for petitions for review in the Rules of Court and other relevant procedures in appeals filed before the Court of Appeals shall be followed in appealed decisions of Special Agrarian Courts. Considering that RA 6657 cannot and does not provide the details on how the petition for review shall be conducted, a suppletory application of the pertinent provisions of the Rules of Court is necessary. In fact, Section 61 uses the word "review" to designate the mode by which the appeal is to be effected. The reference therefore by Section 61 to the Rules of Court only means that the procedure under Rule 42 for petitions for review is to be followed for appeals in agrarian cases.13 (italics in the original; emphasis and underscoring supplied)
The reason why it is permissible to adopt a petition for review when appealing cases decided by the Special Agrarian Courts in eminent domain case is the need for absolute dispatch in the determination of just compensation. Just compensation means not only paying the correct amount but also paying for the land within a reasonable time from its acquisition. Without prompt payment, compensation cannot be considered "just" for the property owner is made to suffer the consequences of being immediately deprived of his land while being made to wait for a decade or more before actually receiving the amount necessary to cope with his loss. Such objective is more in keeping with the nature of a petition for review.
Unlike an ordinary appeal, a petition for review dispenses with the filing of a notice of appeal or completion of records as requisites before any pleading is submitted. A petition for review hastens the award of fair recompense to deprived landowners for the government-acquired property, an end not foreseeable in an ordinary appeal. . . .14 (Italics in the original; emphasis and underscoring supplied)
Although appeal is an essential part of our judicial process, it has been held, time and again, that the right thereto is not a natural right or a part of due process but is merely a statutory privilege. Thus, the perfection of an appeal in the manner and within the period prescribed by law is not only mandatory but also jurisdictional and failure of a party to conform to the rules regarding appeal will render the judgment final and executory. Once a decision attains finality, it becomes the law of the case irrespective of whether the decision is erroneous or not and no court - not even the Supreme Court - has the power to revise, review, change or alter the same. The basic rule of finality of judgment is grounded on the fundamental principle of public policy and sound practice that, at the risk of occasional error, the judgment of courts and the award of quasi-judicial agencies must become final at some definite date fixed by law.15 (emphasis and underscoring supplied)
Endnotes:
1 Records, pp. 1-11.
2 Id. at 240-244. Penned by Judge Ismael P. Casabar.
3 G.R. No. 148223, November 25, 2004.
4 Records, pp. 257-258.
5 Id. at 260-262.
6 Rollo, pp. 131-135
7 G.R. No. 143275, September 10, 2002, 388 SCRA 537.
8 CA rollo, pp. 178-181.
9 Id. at 3-46.
10 Id. at 363.
11 Supra note 7.
12 "An Act Instituting A Comprehensive Agrarian Reform Program To Promote Social Justice And Industrialization Providing The Mechanism For Its Implementation, And For Other Purposes."
13 388 SCRA 537, 544-545.
14 Id. at 546.
15 Zamboanga Forest Managers Corp. v. New Pacific Timber and Supply Co., et al., G.R. No. 143275, 399 SCRA 376, 385.