Case Digest (G.R. No. 229079)
Case Digest (G.R. No. 229079)
Facts:
Development Bank of the Philippines v. Land Bank of the Philippines and Department of Agrarian Reform Adjudication Board, G.R. Nos. 229274 and 229289, June 16, 2021, Supreme Court Second Division, Lopez, M., J., writing for the Court.The dispute concerns a 2,225-sq.m. parcel in Barangay Duhat, Bocaue, Bulacan, registered to Development Bank of the Philippines (DBP) under TCT No. T-144547(M). The property was originally owned by Spouses Angel Armando and Remedios Martin, who mortgaged it to DBP in 1979; after default and foreclosure in 1990 DBP acquired and consolidated title in 1992. In 1998 a 1,567-sq.m. portion was placed under the Comprehensive Agrarian Reform Program (CARP) and submitted for valuation for payment of just compensation.
Pursuant to a request from the DAR Provincial Agrarian Reform Office, Land Bank of the Philippines (LBP) prepared a Claims Valuation recommending just compensation of P11,922.32 based on the DAR formula in DAR Administrative Order No. 5-98. DBP rejected the amount; PARAD and later the DAR Adjudication Board (DARAB) sustained LBP’s valuation. DBP then filed a Petition for Determination of Just Compensation before the Regional Trial Court (RTC) of Malolos, sitting as a Special Agrarian Court (SAC), presenting DBP appraisal reports (including a 2009 appraisal valuing the subject portion at P2,100/sq.m.) and photographs. LBP relied on its DAR AO No. 5-98-based computation and supporting administrative documents.
In a Decision dated December 10, 2013, the RTC, after discussing its SAC jurisdiction, upheld the DARAB/LBP valuation and fixed just compensation at P11,922.32. DBP’s motion for reconsideration was denied. On appeal, the Court of Appeals (CA), in a Decision dated August 11, 2016, affirmed with modification: it rejected DBP’s valuation as based on internal bank appraisal methods and on 2009 values, corrected the computation of LBP’s Capitalized Net Income (CNI) factor (observing three crop cycles per year) and fixed just compensation at P18.85/sq.m. (P29,544.01), ordering LBP to pay the unpaid balance with legal interest; the CA denied the parties’ motions for reconsideration in a Resolution dated January 11, 2017. Both banks filed consolidated Petitions for Review on Certiorari under Rule 45, assailing the CA Decision and Resolution.
Issues:
- Did the Court of Appeals commit reversible error in affirming and modifying the RTC’s valuation by relying on LBP’s computation under DAR AO No. 5-98 and fixing just compensation at P18.85/sq.m. (P29,544.01)?
- Was the CA correct in awarding legal interest on the unpaid balance of the just compensation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)