Case Digest (G.R. No. 216920) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case at hand involves the petitioner Land Bank of the Philippines (LBP) contesting the decision of the Court of Appeals (CA) dated January 18, 2010, in CA G.R. SP No. 93518 concerning the just compensation awarded to the respondents, spouses Esteban and Cresencia Chu. The dispute arose from two parcels of agricultural land owned by the Chus located in San Antonio, Pilar, Sorsogon, which were acquired by the government under the agrarian reform program. The first parcel, under Transfer Certificate of Title (TCT) No. T-27062, measured 14.9493 hectares and was acquired under Presidential Decree No. 27 (PD 27), with an initial valuation by LBP of P177,657.98. The second parcel, under TCT No. T-27060, measured 7.7118 hectares and was acquired under Republic Act No. 6657 (RA 6657), valued at P263,928.57 by LBP. The Chu spouses rejected these valuations, thus prompting summary administrative proceedings at the Provincial Agrarian Reform Adjudication Board (PARAD). The PARAD, on Apr Case Digest (G.R. No. 216920) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Case
- The Petitioner, Land Bank of the Philippines (LBP), assailed lower court decisions regarding the valuation of two parcels of agricultural land.
- The Respondents, spouses Esteban and Cresencia Chu, are the registered owners of the disputed properties located in San Antonio, Pilar, Sorsogon.
- The properties were acquired by the government under its agrarian reform program, with one parcel falling under Presidential Decree No. 27 (PD 27) and the other under Republic Act No. 6657 (RA 6657).
- Description of the Properties
- PD 27–Acquired Land
- Covered by Transfer Certificate of Title Nos. T-27060 and T-27062.
- Total area stated is approximately 14.9493 hectares.
- Initially, LBP valued this parcel at P177,657.98 using the formula: Land Value = AGP × ASP × 2.5, where ASP was erroneously taken as P350 instead of the mandated P35.
- RA 6657–Acquired Property
- Consists of a parcel with an area of 7.7118 hectares, covered by a separate portion of TCT No. T-27060.
- LBP’s initial valuation of this property was P263,928.57.
- Respondents rejected LBP’s valuation, prompting summary administrative proceedings.
- Administrative and Lower Court Proceedings
- Administrative Proceedings
- The Provincial Agrarian Reform Adjudication Board (PARAD) conducted summary administrative proceedings under Land Valuation Cases Nos. LV-30-'03 (RA 6657–acquired) and LV-48-'03 (PD 27–acquired).
- The PARAD recomputed the values:
- RA 6657–acquired property at P1,542,360.00 (at a rate of P200,000.00 per hectare), factoring in comparable sales and a Municipal Resolution declaring the area as industrial.
- LBP’s Motion for Reconsideration before PARAD was denied.
- Regional Trial Court (RTC) Proceedings
- LBP filed a Petition for Determination of Just Compensation.
- The RTC, sitting as a Special Agrarian Court, rendered a decision setting just compensation at:
- P2,313,478.00 for the RA 6657–acquired property.
- The RTC’s decision was based on both the factors considered by PARAD and additional evidence regarding the intended economic development of the area.
- Court of Appeals (CA) Ruling
- The CA modified the RTC decision by:
- Upholding the LBP’s valuation for the PD 27–acquired land at P177,657.98 but awarding 12% per annum legal interest.
- LBP’s Motion for Reconsideration before the CA was denied, which eventually led to this Petition for Review on Certiorari.
Issues:
- Applicability and Proper Computation of Valuation Factors
- Whether the valuation for the RA 6657–acquired property was improperly computed by disregarding the mandatory valuation factors under Section 17 of RA 6657 and relevant DAR administrative orders.
- Remand for Re-computation of the PD 27–Acquired Land
- Whether the CA erred in refusing to remand the case to the RTC for a re-computation of the PD 27–acquired land’s valuation pursuant to Section 17 of RA 6657, as amended.
- Issue on the Award and Computation of Interest
- Whether the imposition of legal interest at 12% per annum on the PD 27–acquired land by the CA is proper given the statutory framework and related jurisprudence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)