Case Digest (G.R. No. 190004) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Land Bank of the Philippines v. Eugenio Dalauta (G.R. No. 190004, August 8, 2017), respondent Eugenio Dalauta was registered owner of a 25.2160-hectare agricultural parcel in Florida, Butuan City, titled under TCT No. T-1624. Under the Comprehensive Agrarian Reform Program (“CARP”), the Department of Agrarian Reform (DAR) issued a Notice of Coverage on January 17, 1994. The Land Bank of the Philippines (LBP) offered P192,782.59 as just compensation, which Dalauta rejected. After a summary administrative proceeding before the Provincial Agrarian Reform Adjudicator (PARAD) of Butuan City confirmed LBP’s valuation on December 4, 1995, Dalauta filed on February 28, 2000 a petition with the Regional Trial Court (RTC), sitting as a Special Agrarian Court (SAC), for determination of just compensation under DAR Administrative Order No. 6, series of 1992. The SAC appointed commissioners whose report valued the land at P100,000.00 per hectare. At trial, Dalauta introduced evidence of a Case Digest (G.R. No. 190004) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Subject Property and Coverage
- Respondent Eugenio Dalauta owned a 25.2160-hectare agricultural parcel in Florida, Butuan City (TCT No. T-1624).
- DAR issued a CARP Notice of Coverage dated January 17, 1994 (received February 7, 1994) subjecting the land to compulsory acquisition.
- Administrative Offers and Proceedings
- Land Bank of the Philippines (LBP) offered ₱192,782.59 as just compensation; Dalauta rejected it.
- The Provincial Agrarian Reform Adjudicator (PARAD) conducted summary proceedings and, in a December 4, 1995 Resolution, affirmed LBP’s valuation.
- RTC/SAC Proceedings
- Dalauta filed a petition with the Regional Trial Court sitting as Special Agrarian Court (SAC) on February 28, 2000, claiming LBP’s valuation violated DAR A.O. No. 6, s. 1992.
- The SAC appointed commissioners who inspected the land and recommended ₱100,000 per hectare.
- Evidence adduced:
- Dalauta claimed a 1993 net income of ₱350,000 from falcata tree sales.
- LBP’s appraisers testified the land was largely idle and valued it using the MV×2 formula.
- SAC Decision (May 30, 2006)
- Applied formula LV = (CNI ÷ .12 × 0.9) + (MV × 0.1); computed ₱2,639,557.00 for land plus ₱100,000 for a farmhouse.
- Awarded ₱150,000 attorney’s fees, ₱50,000 litigation expenses, and commissioners’ fees.
- CA Decision (September 18, 2009)
- Held SAC jurisdiction proper; upheld the DAR A.O. No. 6 formula for land valuation.
- Deleted the farmhouse award, attorney’s fees, and litigation expenses.
- Reduced commissioners’ fees to ₱3,000 each; otherwise affirmed.
- Rule 45 Petition to the Supreme Court
- LBP challenged SAC jurisdiction in view of the PARAD decision’s finality and the 15-day DARAB rule.
- LBP also contested the computation of just compensation.
Issues:
- Jurisdiction
- Did the SAC have original and exclusive jurisdiction despite the PARAD decision’s finality and the 15-day DARAB reglementary period?
- Prescription
- Is there a prescriptive period for filing a petition for judicial determination of just compensation, and if so, what is it?
- Just Compensation
- Did the SAC (and the CA) correctly compute just compensation under RA 6657, DAR A.O. No. 6, and other relevant guidelines?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)