Case Digest (G.R. No. 187307)
Facts:
The case involves Land Bank of the Philippines (LBP) as the petitioner and Del Moral, Inc. as the respondent. Del Moral is a domestic corporation owning several parcels of land in Pangasinan, originally tobacco farmlands, totaling 125.2717 hectares. Of this, 102.9766 hectares were placed under the agrarian reform program pursuant to Presidential Decree No. 27 (P.D. No. 27) enacted in 1972, which sought to transfer land ownership to tenant farmers. Executive Order No. 228 (E.O. No. 228) was issued in 1987, providing for full land ownership to qualified farmer-beneficiaries covered by P.D. No. 27, and setting guidelines for valuation and payment of just compensation to landowners.
The Department of Agrarian Reform (DAR) computed just compensation to Del Moral in the amount of ₱342,917.81, which LBP accepted and informed Del Moral of its claim approval in 1992. Dissatisfied with the low compensation, Del Moral filed a petition in 2002 before the Regional Trial Court (RTC) in Urdan
Case Digest (G.R. No. 187307)
Facts:
- Parties and Property Subject
- Del Moral, Inc. (Del Moral), a domestic family corporation, owned several parcels of land in Pangasinan totaling approximately 125.2717 hectares, originally used as tobacco farmlands.
- Of these, 102.9766 hectares were covered by the agrarian reform program under Presidential Decree (P.D.) No. 27.
- Legal and Administrative Context
- Executive Order (E.O.) No. 228 (1987) declared full land ownership to qualified farmer-beneficiaries under P.D. No. 27, determined the value of remaining unvalued rice and corn lands subject to P.D. No. 27, and prescribed manner of payment and compensation.
- Pursuant to E.O. No. 228, the Department of Agrarian Reform (DAR) computed just compensation due Del Moral at P342,917.81 (circa early 1990s).
- In 1992, the Land Bank of the Philippines (LBP), petitioner and monetary claimant for the government, informed Del Moral of the approval of its claim and assigned the same amount of P342,917.81 as just compensation.
- Dispute and Judicial Proceedings
- Del Moral contested the valuation as grossly inadequate and filed a petition before the Regional Trial Court (RTC), Urdaneta City, in Agrarian Case No. U-1505 on April 26, 2002 for proper determination of just compensation.
- The RTC ruled on October 16, 2006 to compute just compensation based on the recent fair market value using DAR Administrative Order (A.O.) No. 5 (Series of 1998), fixing the amount at P216,104,385.00. It also awarded P90 million temperate damages and P10 million nominal damages, plus 6% legal interest from finality of judgment until full payment.
- Motions for reconsideration by DAR and LBP were denied by the RTC.
- Appeals Before Court of Appeals (CA) and Supreme Court (SC)
- DAR appealed to the CA (CA-G.R. SP No. 98373), which affirmed RTC decision but reduced charges to P10 million temperate damages and P1 million nominal damages (October 30, 2007).
- The Supreme Court (SC) denied DAR’s petition for review for lack of procedural compliance (June 4, 2008), making the CA decision final and executory (October 28, 2008).
- LBP filed a separate appeal to the CA (CA-G.R. SP No. 98033), which denied LBP’s appeal and confirmed RTC and DAR/CA rulings (May 9, 2008).
- The CA also denied LBP’s motion for reconsideration (March 26, 2009), prompting LBP to file the present petition.
- Writ of Execution and LBP's Motion for TRO
- Following finality of decisions, Del Moral filed a motion for execution (March 12, 2009).
- LBP opposed, claiming it was not made a party to prior appeals and challenged RTC jurisdiction over issuance of writ of execution.
- The RTC granted execution motion, reasoning the obligation of LBP and DAR is joint and several concerning agrarian reform compensation.
Issues:
- Whether the LBP is bound by the final and executory judgment against the DAR regarding the computation of just compensation and awards for damages?
- Whether the just compensation awarded to Del Moral was properly computed?
- Whether the awards for temperate and nominal damages, as well as the imposition of legal interest, are proper?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)