Case Digest (G.R. No. 196412)
Facts:
Land Bank of the Philippines v. Miguel Omengan, G.R. No. 196412, July 19, 2017, Third Division, Tijam, J., writing for the Court.
Petitioner Land Bank of the Philippines (LBP) sought review of the Court of Appeals' Decision dated January 6, 2011 and Resolution dated April 7, 2011 (CA‑G.R. SP No. 110387) affirming with modification the Regional Trial Court of Bulanao, Tabuk City, Branch 25, sitting as Special Agrarian Court's (RTC‑SAC) Decision dated January 6, 2009 in an agrarian‑expropriation case; LBP brought the case to the Supreme Court by a Rule 45 petition for review.
Respondent Miguel Omengan was the registered owner of a 10.001‑hectare parcel in Ileb, Nambaran, Tabuk City (TCT No. T‑10172). On March 20, 2000 the Department of Agrarian Reform (DAR) issued a notice of coverage under CARP. LBP conducted a field investigation and initially valued the property at Php 219,524.98; after respondent rejected DAR's offer, LBP deposited that amount in cash and agrarian reform bonds on December 12, 2000.
In July 2005 the Provincial Adjudicator (PARAD) issued a decision increasing valuation to Php 326,918.20 but, on motion for reconsideration, reversed that ruling on September 12, 2005 and adopted LBP's valuation of Php 264,458.74. LBP filed a petition for judicial determination of just compensation before the RTC‑SAC on August 12, 2005.
The RTC‑SAC (Decision Jan. 6, 2009) fixed just compensation at Php 706,850 for the 10.001 has., awarding legal interest at 12% per annum from date of taking. LBP's MR was denied (Resolution July 31, 2009). The Court of Appeals in CA‑G.R. SP No. 110387 affirmed the RTC‑SAC's valuation but reduced the interest rate to 6% per annum (citing DAR A.O. No. 13‑94) and denied LBP&#...(Pro-only)
Issues:
- Did the RTC‑SAC comply with the valuation formula prescribed under DAR A.O. No. 5‑98 (implementing Section 17, R.A. No. 6657) in determining just compensation, or did it deviate without adequately explaining the deviation?
- Was the Court of Appeals correct to impose interest at six percent (6%) per annum on the award of just compensation pursuant to DAR A.O. No. 13‑94, or sh...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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