Case Digest (G.R. No. 190004)
Facts:
Land Bank of the Philippines v. Eugenio Dalauta, G.R. No. 190004, August 08, 2017, the Supreme Court En Banc, Mendoza, J., writing for the Court.
Respondent Eugenio Dalauta was the registered owner of a 25.2160-hectare agricultural parcel in Florida, Butuan City (TCT No. T-1624). The Department of Agrarian Reform (DAR) placed the land under compulsory acquisition under the Comprehensive Agrarian Reform Program (Notice of Coverage dated January 17, 1994, received February 7, 1994). Land Bank of the Philippines (LBP) made a preliminary offer of P192,782.59 as compensation, which Dalauta rejected.
Pursuant to RA No. 6657 procedures, the matter went to a summary administrative proceeding before the Provincial Agrarian Reform Adjudicator (PARAD), whose Resolution (December 4, 1995) affirmed LBP’s valuation. Dalauta then filed a petition for judicial determination of just compensation with the Regional Trial Court, Branch 5, Butuan City, sitting as Special Agrarian Court (SAC), on February 28, 2000, challenging the valuation as inconsistent with DAR A.O. No. 6 (1992).
The SAC appointed a Board of Commissioners to inspect the property; their report (July 10, 2002) recommended a value pegged at P100,000.00 per hectare. At trial Dalauta testified he had realized net proceeds of P350,000.00 in 1993 from sale of falcata trees on the land and presented an agreement, deposit slip and bank certification; he described 21 hectares as planted with trees and 4 hectares for corn. LBP’s witnesses (an LBP appraiser and agrarian operations specialist) testified the land had no income-producing activity warranting a Capitalized Net Income (CNI) calculation and used DAR A.O. No. 6’s MV x 2 formula to arrive at P192,782.59.
On May 30, 2006 the SAC rendered judgment awarding P2,639,557.00 as land value (using a CNI-based formula), P100,000.00 for a farmhouse, attorney’s fees (P150,000.00), litigation expenses (P50,000.00), and commissioners’ fees. LBP’s motion for reconsideration was denied July 18, 2006.
LBP appealed to the Court of Appeals (CA) via a petition for review under Rule 42, arguing (inter alia) lack of SAC jurisdiction because the PARAD resolution had attained finality, improper reception of the Commissioners’ report and erroneous application of RA No. 6657 and DAR A.O. No. 6. The CA (Sept. 18, 2009) held the SAC properly took cognizance (citing LBP v. Wycoco and LBP v. Suntay), affirmed the SAC’s valuation generally but deleted the farmhouse and awards for attorney’s fees and litigation expenses and reduced the commissioners’ fees to P3,000.00 each — the CA partially granted LBP’s petition and modified the SAC decision.
L...(Pro-only)
Issues:
- Did the Regional Trial Court, sitting as Special Agrarian Court (SAC), properly take cognizance of Dalauta’s petition for determination of just compensation despite the PARAD resolution allegedly having attained finality?
- Was the SAC’s computation of just compensation for the subj...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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