Case Digest (G.R. No. 192345)
Facts:
Land Bank of the Philippines v. Spouses Esteban and Cresencia Chu, G.R. No. 192345, March 29, 2017, the Supreme Court First Division, Del Castillo, J., writing for the Court.The petition arises from two parcels of agricultural land in San Antonio (Sapa), Pilar, Sorsogon owned by Spouses Esteban and Cresencia Chu. One parcel (TCT Nos. T‑27060 and T‑27062) of 14.9493 hectares was placed under Presidential Decree No. 27 (PD 27-acquired land); the other (part of TCT No. T‑27060) of 7.7118 hectares was taken under Republic Act No. 6657 (RA 6657-acquired property). Land Bank of the Philippines (LBP) initially valued the PD 27 parcel at P177,657.98 and the RA 6657 parcel at P263,928.57; the landowners rejected those valuations.
The matter proceeded to summary administrative valuation before the Provincial Agrarian Reform Adjudication Board (PARAD) as Land Valuation Cases LV‑48‑'03 (PD 27 land) and LV‑30‑'03 (RA 6657 land). On April 11, 2003 the PARAD recomputed values: it fixed the RA 6657 parcel at P1,542,360.00 (P200,000/ha) based on comparable sales and a municipal resolution declaring Hacienda Chu an industrial area, and it valued the PD 27 parcel at P983,663.94 using the PARAD formula (land value = AGP x ASP x 2.5). LBP’s motion for reconsideration before the DARAB was denied on June 19, 2003.
LBP filed a Petition for Determination of Just Compensation in the Regional Trial Court (RTC) of Sorsogon City, Branch 52 (Civil Case No. 2003‑7205). In a September 21, 2005 Decision the RTC, acting as Special Agrarian Court (SAC), fixed just compensation at P2,313,478.00 for the RA 6657 parcel and P1,155,173.00 for the PD 27 parcel, adding amounts to reflect the parcels’ alleged “potentials” and economic developments in the area. The RTC denied LBP’s motion for reconsideration on February 13, 2006.
On appeal, the Court of Appeals (CA) modified the RTC. For the PD 27 land the CA held the PARAD formula correct but reduced the ASP used, applying precedent to conclude the correct ASP was P35 (per Executive Order No. 228 as interpreted in Gabatin v. Land Bank of the Philippines) and thus upheld LBP’s lower valuation of P177,657.98 but awarded legal interest at 12% per annum. For the RA 6657 land the CA applied the DAR formula implementing Section 17 of RA 6657 (as reflected in DAR A.O. No. 05‑98) and affirmed P200,000/ha (P1,542,360). The CA entered its ruling (Jan. 18, 2010) and denied LBP’s motion for reconsideration (May 24, 2010).
LBP filed a Petition for Review on Certiorari under Rule...(Pro-only)
Issues:
- Under Rule 45, may the Court re-examine factual findings and receive new evidence, or are only questions of law reviewable?
- Did the Court of Appeals err in fixing just compensation for the RA 6657‑acquired land at P1,542,360.00 by disregarding Section 17 of RA 6657 and DAR A.O. No. 05‑98?
- Did the Court of Appeals err in refusing to remand the PD 27‑acquired land to the RTC for recomputation under Section 17 of RA 6657, as amended, and applicable DAR issuances?
- Was the CA wrong to impose interest at 12% per annum on ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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