Case Digest (G.R. No. 164195)
Facts:
The case Apo Fruits Corporation and Hijo Plantation, Inc. v. Hon. Court of Appeals and Land Bank of the Philippines originated before the Third Division of the Supreme Court, which rendered its initial decision on February 6, 2007. The respondents, Land Bank of the Philippines (LBP), sought modifications to this decision, which led to a further resolution on December 19, 2007, wherein the court deleted the awards for interest and attorney's fees.
The antecedents of this case trace back to October 12, 1995, when petitioners Apo Fruits Corporation (AFC) and Hijo Plantation, Inc. (HPI) voluntarily offered lands for sale under Republic Act No. 6657, known as the Comprehensive Agrarian Reform Law (CARL). The Department of Agrarian Reform (DAR) subsequently referred their voluntary-offer applications to LBP for valuation. The compensation set by LBP—P165,484.47 per hectare—was rejected by AFC and HPI. Consequently, LBP opened deposit accounts for the petitioners, allowing them to
Case Digest (G.R. No. 164195)
Facts:
- On October 12, 1995, Apo Fruits Corporation (AFC) and Hijo Plantation, Inc. (HPI) voluntarily offered to sell the lands subject to the dispute pursuant to Republic Act No. 6657 (Comprehensive Agrarian Reform Law).
- The Department of Agrarian Reform (DAR) referred their Voluntary-Offer-to-Sell (VOS) applications to the Land Bank of the Philippines (LBP) for an initial valuation.
- LBP fixed the just compensation at ₱165,484.47 per hectare, amounting to ₱86,900,925.88 for AFC and ₱164,478,178.14 for HPI.
Voluntary Offer and Initial Valuation
- Rejecting the initial valuation, DAR advised LBP to open deposit accounts in the petitioners’ names, crediting them with ₱26,409,549.86 (AFC) and ₱45,481,706.76 (HPI).
- Both petitioners withdrew these amounts in cash from the respective accounts.
- Subsequently, on February 14, 1997, AFC and HPI filed separate complaints for the determination of just compensation with the DAR Adjudication Board (DARAB).
- When DARAB did not act on these complaints for more than three years, both petitioners instituted separate actions before the Regional Trial Court (RTC) in Tagum City, Branch 2, acting as a Special Agrarian Court.
Deposits, Withdrawals, and Filing of Complaints
- The RTC conducted a pretrial, appointed court‑appointed commissioners deemed competent and disinterested, and evaluated the valuation of the properties involved.
- On September 25, 2001, the RTC issued its decision, determining and fixing the just compensation for 1,388.6027 hectares of land and improvements owned by the petitioners.
- The decision ordered:
- Joint and several payment by the defendants (DAR and LBP) of the determined just compensation.
- Payment of legal interest on the just compensation, originally linked to market rates (91‑day Treasury Bills), computed from the taking date.
- Payment of the commissioners’ fees and attorney’s fees (the latter originally computed at 10% of the just compensation), as well as deduction of any initial deposit previously credited.
- Payment of costs through the Clerk of Court to cover any docket fee deficiency.
Regional Trial Court Proceedings and Decision
- Respondent LBP filed a motion for reconsideration which resulted on December 5, 2001, in modifications of the RTC’s order:
- The interest computed at 12% per annum on the just compensation was replaced by a new computation tied solely from the filing of the complaint.
- The commissioners’ fees order was slightly modified.
- The award for attorney’s fees was deleted.
- LBP attempted to appeal the RTC decision by filing a notice of appeal; however, the RTC held that the proper mode of appeal was by petition for review, per the ruling in Land Bank of the Philippines v. De Leon.
- LBP then resorted to a petition for certiorari before the Court of Appeals (CA) to assail the RTC order denying due course to its appeal. The CA eventually granted LBP’s petition (noting procedural and substantive issues) and nullified the RTC’s corresponding orders.
- After the CA denied the joint motion for reconsideration on June 21, 2004, AFC and HPI appealed on certiorari and raised several issues regarding the legality, proper mode of appeal, and alleged delay or due process violations.
- On February 6, 2007, the Third Division of the Supreme Court partially granted the petition by affirming the underlying RTC decision while concurrently giving due course to the pending petition on its merits.
- LBP then sought reconsideration of the deletion of the award for legal interest and attorney’s fees. On December 19, 2007, the Third Division partially granted LBP’s motion for reconsideration, expressly deleting the award of interest and attorney’s fees and remanding the issue of commissioners’ fees.
- Despite filing several further motions (including a second motion for reconsideration and a motion for referral to the Court en banc), the parties did not succeed in reversing these modifications, and the entry of judgment was made on May 16, 2008.
Motion for Reconsideration and Subsequent Appeals
Issue:
- Whether the questioned decision and resolution are in accord with existing law and applicable Supreme Court precedents.
- Whether the modifications made by the RTC and subsequently by the Third Division, particularly the deletion of the award for legal interest and attorney’s fees, are proper intervention upon a final judgment.
Legality and Consistency of the Decision
- Whether LBP is bound by prior decisions, such as the CA ruling in CA-G.R. SP No. 74879, hence precluding it from filing CA-G.R. SP No. 76222.
- Whether the filing by LBP of CA-G.R. SP No. 76222 is already barred by res judicata.
- The applicability of the Supreme Court’s ruling in the Arlene de Leon case on the proper mode of appeal from decisions of Special Agrarian Courts.
Mode of Appeal and Procedural Validity
- Whether respondent LBP was deprived of due process or of its right to appeal by the manner in which the proceedings were conducted.
- Whether the petition for review and motions filed by AFC and HPI were merely interposed to delay execution of the Special Agrarian Court’s decision based on evidence already duly presented and adjudicated.
Due Process and Timing
- Whether AFC and HPI are entitled to recover legal interest due to alleged delays in payment of just compensation.
- Whether the award of attorney’s fees should be reinstated, notwithstanding the modifications and findings that LBP complied promptly with its payment obligations.
Award of Interest and Attorney’s Fees
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)