Case Digest (G.R. No. 187307)
Facts:
Land Bank of the Philippines v. Del Moral, Inc., G.R. No. 187307, October 14, 2020, Supreme Court Second Division, Hernando, J., writing for the Court.Del Moral, Inc. (Del Moral) is the registered owner of several parcels (totaling 125.2717 hectares) in Pangasinan, of which 102.9766 hectares were placed under the agrarian reform coverage of Presidential Decree No. 27 (P.D. No. 27). Pursuant to Executive Order No. 228 (July 17, 1987), the Department of Agrarian Reform (DAR) computed just compensation at P342,917.81 (about P3,329.30 per hectare). In 1992 the Land Bank of the Philippines (LBP) informed Del Moral of approval of its monetary claim and assigned that valuation; Del Moral protested that the amount was grossly inadequate.
Del Moral filed a petition on April 26, 2002 before the Regional Trial Court (RTC), Urdaneta City, Branch 45, sitting as a Special Agrarian Court (Agrarian Case No. U-1505), for proper determination of just compensation. On October 16, 2006 the RTC computed just compensation using a contemporary fair market value approach (applying the DAR formula in A.O. No. 5, series of 1998) and fixed just compensation at P216,104,385.00; it also awarded P90 million temperate damages, P10 million nominal damages, and 6% legal interest from finality.
The DAR and the LBP separately appealed to the Court of Appeals (CA). The DAR’s appeal was docketed CA-G.R. SP No. 98373; the LBP’s appeal was CA-G.R. SP No. 98033. On October 30, 2007 the CA in CA-G.R. SP No. 98373 affirmed the RTC’s computation but reduced temperate and nominal damages to P10 million and P1 million, respectively, applying principles from Lubrica v. Land Bank of the Philippines and related Supreme Court jurisprudence that when payment of just compensation is long delayed the valuation should be based on market value at the time of payment and that R.A. No. 6657 (the Comprehensive Agrarian Reform Law) governs incomplete processes begun under P.D. No. 27.
The DAR sought review in this Court (G.R. No. 181183), but this Court denied the petition on June 4, 2008 for procedural defects; the denial became final and executory with an Entry of Judgment on October 28, 2008. Meanwhile, the CA in CA-G.R. SP No. 98033 (the LBP appeal) promulgated its Decision on May 9, 2008, which likewise affirmed the RTC’s computation (but adjusted damages to match its prior ruling). The CA denied the LBP’s motion for reconsideration in a Resolution dated March 26, 2009.
Following finality of the DAR-related proceedings, Del Moral moved for execution (March 12, 2009). The RTC granted execution, reasoning that LBP, as custodian of the Agrarian Reform Fund, was bound by the final judgment affecting the government’s interest. LBP filed an urgent verified motion for a TRO/preliminary injunction with the Supreme Court (May 26, 2009) seeking to enjoin enforcement of the writ of execution, and thereafter filed the present Petition for review (G.R. No. 187307) challenging the CA decision in CA-G.R. SP No. 98033 and contending, inter alia, that (a) res judicata does not bind LBP; (b) the courts erred in com...(Subscriber-Only)
Issues:
- Is the LBP bound by the final and executory judgment against the DAR (res judicata / law of the case)?
- Was the just compensation to be paid to Del Moral properly computed (timing and formula; application of Section 17, R.A. No. 6657; effect of R.A. No. 9700)?
- Are the awards for temperate and nominal damages and the impositio...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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