G.R. No. 196264 - Land Bank of the Philippines vs. Navarro

Lina B. Navarro (respondent), daughter of Antonio Buenaventura and stepdaughter of Jovita Buenaventura, owned a 25% pro-indiviso share of Lot No. 6561, Cad-174, Guianga Cadastre, Catalunan Grande, Davao City.
Antonio and Jovita owned the property, an agricultural land of 29.0772 hectares, covered by Original Certificate of Title No. P-2182.
Upon Antonio’s death, Jovita was appointed administratix of his estate; the property was partitioned between Jovita (75%) and Lina (25%).

In 1988, pursuant to Presidential Decree No. 27 (PD 27), the government expropriated 21.890 hectares of Lot No. 6561 for agrarian reform.
The Department of Agrarian Reform (DAR) valued the expropriated land at ₱49,025.15 based on the Landowner-Tenant Production Agreement and Farmer’s Undertaking between Jovita and tenant-beneficiaries.
The Land Bank of the Philippines (LBP), petitioner, agreed with this valuation. Jovita was paid ₱36,768.86; Lina rejected the tender of ₱12,256.29 for her 25% share, considering it confiscatory.

On August 9, 1995, Lina filed a petition with the Regional Trial Court, acting as Special Agrarian Court (SAC), for fixation of just compensation against DAR and LBP.
Lina alleged the DAR’s valuation was ridiculously low (₱0.17 per sq. m.) and violated her rights to just compensation and due process.
She requested that comparable sales of nearby properties be considered in valuation.
LBP denied the claim that the valuation was confiscatory, insisting the property’s valuation complied with PD 27 as amended by EO 228, and argued the property was not physically subdivided, making the identification of Lina’s portion impossible.
The DAR maintained their valuation was fair and argued Lina failed to exhaust administrative remedies. Lina countered that exhaustion did not apply to her case.

Out of 29.0772 hectares of Antonio’s estate, 21.890 hectares were subjected to DAR coverage under PD 27, evidenced by Emancipation Patents (EPs) 221 to 234.
Of these, 6.5006 hectares were directly paid by tenants to Jovita, covering part of her 75% share. The balance of 15.2999 hectares was paid by government via LBP.
Lina’s compensable share is 25% of the 21.890 hectares, equating to 5.4725 hectares.

The area taken was 234,702 sq. m. (23.4702 hectares), from which Lina’s 25% share was 58,675.50 sq. m. (5.807 hectares).
Date of taking was June 13, 1988, corresponding with the issuance of the EPs and cancellation of the OCT.
Just compensation was fixed at ₱10.00 per sq. m., applying the market value approach.
Legal interest of 12% per annum was imposed from date of taking until full payment.

Lina moved for execution pending appeal due to age, sickness, and long delay; the CA granted this.
Dispute arose over the actual land area covered; Lina alleged a typographical error in total hectares, contending it should be 21.8005 hectares instead of 21.890. The CA agreed, reducing Lina’s share to 5.4501 hectares.
LBP contested the area subject to government acquisition, claiming only 15.2999 hectares financed by them, excluding the 6.5006 hectares paid directly by tenants covering Jovita’s share.
The CA held LBP was bound by the stipulation and that Lina’s 25% share should be computed based on the total 21.8005 hectares.
The CA affirmed the SAC’s valuation and date of taking, noting just compensation should now be governed by RA 6657 (Comprehensive Agrarian Reform Law), as amended by RA 9700.
The CA ordered LBP to pay for the remaining 1.7 hectares at ₱10.00 per sq. m. plus 12% interest per annum from June 13, 1988 until fully paid.
LBP filed a motion for reconsideration and later a manifestation invoking RA 9700 but the CA denied the motion.

Whether Lina’s compensable share is correctly fixed at 5.4725 (later corrected to 5.4501) hectares.
Whether the just compensation fixed by the SAC and affirmed by the CA is proper, particularly if Section 17 of RA 6657 and the DAR valuation formula were correctly applied.
Whether the imposition of 12% legal interest per annum on the just compensation is appropriate.