Title
Apo Fruits Corp. vs. Land Bank of the Philippines
Case
G.R. No. 164195
Decision Date
Apr 5, 2011
Landowners AFC and HPI contested LBP's undervaluation of their lands under CARL. SC upheld 12% interest for delayed just compensation, citing LBP's gross undervaluation and 12-year delay.

Case Digest (G.R. No. 164195)

Facts:

Apo Fruits Corporation and Hijo Plantation, Inc. v. Land Bank of the Philippines, G.R. No. 164195, April 05, 2011, the Supreme Court En Banc, Brion, J., writing for the Court.

Apo Fruits Corporation (AFC) and Hijo Plantation, Inc. (HPI) offered lands to the government under Republic Act No. 6657 (CARL) in October 1995. The Land Bank of the Philippines (LBP) initially valued the lands at substantially lower amounts and deposited partial payments pursuant to DAR instructions; the petitioners rejected these amounts and sought administrative determination of just compensation before the DAR Adjudication Board (DARAB), which was inactive for years, prompting petitions to the Regional Trial Court (RTC) of Tagum.

The RTC fixed just compensation at a figure far higher than LBP’s initial valuation and ordered 12% interest from taking; on September 25, 2001 it rendered judgment awarding P1,383,179,000.00 and interest. The Court’s Third Division affirmed the RTC in a February 6, 2007 decision but, in a December 19, 2007 resolution on motions for reconsideration, the Third Division deleted the 12% interest and attorney’s fees; motions for reconsideration were denied April 30, 2008, and entry of judgment followed May 16, 2008.

The petitioners filed a second motion for reconsideration with the Third Division and sought en banc reconsideration; the Division referred the matter to the Court en banc. The Court en banc initially denied that second motion on December 4, 2009. The petitioners nevertheless filed another motion (later characterized as a third motion for reconsideration), and on October 12, 2010 the Court en banc (by a vote recorded in the records) granted the motion and restored the 12% interest award. The Court subsequently denied LBP’s motion for reconsideration (November 23, 2010), prompting LBP’s 2nd Motion for Reconsideration of December 14, 2010 and a request for oral arguments; the Office of the Solicitor General (OSG) filed a motion to intervene on behalf of the Republic on February 15, 2011.

By the present Resolution (April 05, 2011), the Court en banc, Brion, J., r...(Pro-only)

Issues:

  • Was LBP’s December 14, 2010 second motion for reconsideration properly entertainable, or barred by the Rules prohibiting second motions for reconsideration and by the Court’s Internal Rules (Section 3, Rule 15)?
  • Did the Court correctly award 12% interest on the unpaid balance of just compensation for delay attributable to the government?
  • Should the Court have allowed oral arguments on LBP’s motion?
  • Should the OSG have been permitted to intervene at that l...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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