Facts:

The case involves Apo Fruits Corporation and Hijo Plantation, Inc. (collectively referred to as "petitioners") as the petitioners and the Land Bank of the Philippines (LBP) as the respondent. The events leading to this case began when the petitioners voluntarily offered to sell their agricultural lands to the government under Republic Act No. 6657, known as the Comprehensive Agrarian Reform Law (CARL). The LBP initially valued the properties at P165,484.47 per hectare for Apo Fruits and P201,929.97 per hectare for Hijo Plantation, which the petitioners rejected. Subsequently, the LBP made partial payments totaling P71,891,256.62, which the petitioners accepted. However, the petitioners filed complaints for just compensation with the Department of Agrarian Reform Adjudication Board (DARAB) due to the LBP's undervaluation of their properties. After a prolonged legal battle, the Regional Trial Court (RTC) of Tagum City ruled in favor of the petitioners on September...

Facts:

Expropriation and Valuation of Properties

• Petitioners, APO Fruits Corporation and Hijo Plantation, Inc. (AFC and HPI), had their agricultural properties expropriated by the government under the agrarian reform program.
• The dispute centered on the valuation of these properties. Initially, Land Bank of the Philippines (LBP) valued the lands at a significantly lower rate compared to the valuation later determined by the Regional Trial Court (RTC).
• The RTC, in its Decision of February 6, 2007, fixed just compensation at an amount substantially higher than the initial valuation, incorporating evidence such as the reports of government commissioners, appraiser reports, market assessments, and comparative sales data.

Procedural History and Motions for Reconsideration

• After the RTC decision, the Third Division of the Supreme Court affirmed the RTC’s valuation and later, in a Resolution dated December 19, 2007, deleted the award of 12% interest on the unpaid balance.
• Despite the entry of judgment on May 16, 2008, petitioners filed subsequent motions for reconsideration aiming to restore the 12% interest awarded by the RTC.
• The petitioners subsequently obtained an award of 12% interest in the Resolution dated October 12, 2010, by a vote of 8 to 4, which reinstated their claim for additional compensation on account of the delay.
• In response, LBP filed its second motion for reconsideration. This motion raised several arguments:
• The test of “transcendental importance” should not apply as the case did not involve issues of life or liberty.
• The standard employed should not override the doctrine of immutability of a final judgment.
• The Court had allegedly ignored deliberations of the 1986 Constitutional Commission regarding just compensation in cases of agricultural expropriation.
• Even assuming the interest award had legal and factual basis, only a 6% interest per annum should be imposed.
• In addition, the Office of the Solicitor General (OSG) moved for leave to intervene and admit a motion for reconsideration-in-intervention on behalf of the Republic.

Delay in Payment and Government Conduct

• The case was marked by allegations of gross negligence on the part of the government for having delayed the payment of just compensation for nearly twelve years.
• Evidence showed that despite initial partial payments made soon after the expropriation, the full compensation was not paid until much later, resulting in a substantial delay.
• The delay also resulted in the accrual of interest, which the petitioners argued should be at 12% per annum given the prolonged period of non-payment.
• The government’s inaction, including a noted undervaluation of the properties by the LBP and a three-year delay by the DAR Adjudication Board, contributed significantly to the extended litigation and delay in compensation.

Issue:

Procedural Validity of Second Motions for Reconsideration

• Whether the Supreme Court could entertain LBP’s second motion for reconsideration after a final judgment had already been entered.
• Whether the Court’s procedure in reviewing such motions complied with Section 2, Rule 52 of the Rules of Court and Section 3, Rule 15 of the Internal Rules of the Supreme Court, particularly in light of the requirement for a vote of at least two-thirds of its actual membership when exceptional circumstances are invoked.

Determination of Interest on Just Compensation

• Whether the imposition of 12% interest per annum on the balance of the expropriated compensation was legally and factually justified.
• Whether the very concept of “transcendental importance” was correctly applied in the context of an eminent domain case involving agrarian reform, which implicates not only private property rights but also public interest considerations.
• Whether the delay in payment—attributed to government inaction and undervaluation—warrants the award of higher interest, as opposed to the alternative argument proposing only 6% per annum.

Separation of Government and Beneficiaries’ Obligations

• Whether the interest payment owed by the government as a result of its delay should be considered separate and distinct from the payment obligations of farmers-beneficiaries under Republic Act No. 6657 (CARL).

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)