Case Digest (G.R. No. 217985-86)
Facts:
Apo Fruits Corporation (Apo) was the registered owner of a 115.2179-hectare land located in San Isidro, Tagum City, Davao del Norte, covered by Transfer Certificate of Title (TCT) No. T-113359. On October 12, 1995, Apo voluntarily offered to sell this property to the government under the Comprehensive Agrarian Reform Program (CARP). The Department of Agrarian Reform (DAR) referred the application to the Land Bank of the Philippines (LBP) for initial valuation. On October 16, 1996, Apo received a Notice of Land Valuation and Acquisition from the DAR, which valued the property at Php 16.5484 per square meter, totaling Php 165,484.47 per hectare. Apo found this valuation unsatisfactory and rejected the offer. Subsequently, the DAR requested LBP to deposit an initial payment of Php 3,814,053.53 based on a rate of Php 3.3102 per square meter. The Register of Deeds of Tagum City was directed to cancel TCT No. 113359, which was done on December 9, 1996, transferring the property to ...
Case Digest (G.R. No. 217985-86)
Facts:
Background of the Case
Apo Fruits Corporation (Apo) was the registered owner of a 115.2179-hectare land in San Isidro, Tagum City, Davao del Norte, covered by Transfer Certificate of Title (TCT) No. T-113359. On October 12, 1995, Apo voluntarily offered to sell the property to the government under the Comprehensive Agrarian Reform Program (CARP).
Initial Valuation and Rejection
The Department of Agrarian Reform (DAR) referred Apo to the Land Bank of the Philippines (LBP) for initial valuation. On October 16, 1996, DAR informed Apo that the property was valued at Php 16.5484 per square meter, totaling Php 165,484.47 per hectare. Apo rejected this valuation, deeming it too low.
Government Action and Transfer of Title
Despite Apo's rejection, DAR requested LBP to deposit Php 3,814,053.53 as initial payment. The Register of Deeds of Tagum City subsequently canceled TCT No. 113359 on December 9, 1996, transferring the property to the Republic of the Philippines. Certificates of Land Ownership (CLOAs) were issued to farmer-beneficiaries.
Legal Proceedings
Apo filed a complaint for determination of just compensation with the Department of Agrarian Reform Adjudication Board (DARAB), but the case remained unresolved for six years. On June 20, 2002, Apo filed a complaint before the Regional Trial Court (RTC) of Tagum City, acting as a Special Agrarian Court (SAC).
Commissioners' Report
The RTC appointed commissioners to determine the property's value. The commissioners, after considering various factors, recommended a valuation of Php 134.42 per square meter, later adjusted to Php 130.00 per square meter, totaling Php 149,783,000.27 for the entire property.
RTC Decision
On February 25, 2005, the RTC adopted the commissioners' recommendation, ordering LBP and DAR to pay Apo Php 149,783,000.27 as just compensation, plus interest, attorney's fees, and commissioners' fees.
CA Decision
The Court of Appeals (CA) modified the RTC decision, setting the just compensation at Php 103.33 per square meter and limiting the 12% interest to the period from December 9, 1996, to May 9, 2008.
Issue:
- Whether the CA erred in setting the just compensation at Php 103.33 per square meter, contrary to the commissioners' and RTC's recommendation of Php 130.00 per square meter.
- Whether the 12% interest on unpaid just compensation should be computed from December 9, 1996 (the time of taking) until full payment, or only until May 9, 2008, as ruled by the CA.
Ruling:
The Supreme Court ruled in favor of Apo, modifying the CA decision as follows:
- The just compensation for the subject property is set at Php 130.00 per square meter, totaling Php 149,783,270.00.
- LBP is ordered to pay 12% legal interest per annum on the unpaid balance from December 9, 1996, to June 30, 2013. From July 1, 2013, until full payment, the interest rate is reduced to 6% per annum.
- The award of 10% attorney's fees in favor of Apo is affirmed.
Ratio:
- (Unlock)