Title
Hacienda Luisita, Inc. vs. Presidential Agrarian Reform Council
Case
G.R. No. 171101
Decision Date
Dec 9, 2020
HLI sought just compensation for land under CARP after SDP revocation. Audit found no distributable balance for FWBs; Court upheld ARF use, Torrens titles, and HLI's entitlement to compensation.

Case Digest (G.R. No. 171101)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case:
    • Hacienda Luisita Incorporated (HLI) filed a Motion for Payment of Just Compensation regarding its agricultural land, which was placed under compulsory coverage under the Comprehensive Agrarian Reform Program (CARP).
    • The Court previously upheld the revocation of HLI's Stock Distribution Plan (SDP) and ordered the distribution of its agricultural land to qualified farmworker-beneficiaries (FWBs).
  • Main Decision and Resolutions:
    • The Court’s July 5, 2011 decision (Main Decision) revoked HLI’s SDP and ruled that the FWBs’ shares in HLI through the SDP would be canceled.
    • HLI’s agricultural land (4,335.24 hectares) would be distributed to qualified FWBs.
    • FWBs were entitled to retain benefits received and 3% of the proceeds from land transfers, after deducting taxes, transfer costs, and legitimate corporate expenses.
    • HLI was entitled to just compensation for the land transferred to the Department of Agrarian Reform (DAR).
  • Subsequent Incidents:
    • HLI filed a Motion for Payment of Just Compensation on March 30, 2015.
    • PARC/DAR filed a Manifestation requesting HLI to furnish certified true copies of transfer documents related to homelots given to FWBs.
    • A Special Audit Panel was formed to audit HLI’s legitimate corporate expenses.
  • Audit Panel’s Findings:
    • The audit panel determined that HLI’s legitimate corporate expenses exceeded the proceeds from land transfers, leaving no distributable balance for FWBs.
    • The Court ruled on April 24, 2018, that the obligation to distribute the 3% share was fully complied with.
  • Issues Raised:
    • Respondents Mallari and Andaya filed a Motion for Reconsideration, arguing that certain expenses should have been disallowed.
    • HLI sought just compensation for homelots given to FWBs.
    • PARC/DAR raised queries regarding the use of the Agrarian Reform Fund (ARF) and the issuance of titles to FWBs.

Issues:

  • Did the audit panel correctly determine that HLI’s legitimate corporate expenses exceeded the total proceeds from land transfers?
  • Is HLI entitled to just compensation for the homelots given to FWBs?
  • May the DAR use the Agrarian Reform Fund (ARF) to pay just compensation to HLI?
  • What title should be issued to FWBs who received certificates of award but not certificates of title for their homelots? Is the DAR mandated to issue Certificates of Land Ownership Award (CLOAs)?
  • Are certified true copies of transfer documents necessary for the completion of DAR’s validation procedures?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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