Case Digest (G.R. No. 213161)
Facts:
Land Bank of the Philippines v. Spouses Rene I. Latog and Nelda Lucero, G.R. No. 213161, February 01, 2023, Supreme Court Third Division, Gaerlan, J., writing for the Court. Petitioner is Land Bank of the Philippines (LBP); respondents are Spouses Rene I. Latog and Nelda Lucero (respondents), owners of the subject titles.The dispute concerns two parcels (Lot Nos. 6003 and 6004) totaling about 16.1089 hectares in Cabatangan, Lambunao, Iloilo, covered by TCT No. T-86890 in the respondents' names. Respondents voluntarily offered the parcels for acquisition under Republic Act No. 6657 (Comprehensive Agrarian Reform Law, CARL) at P150,000 per hectare; LBP evaluated and recommended lower amounts using an alternate DAR formula (LV = CNI(0.90) + MV(0.10)), arriving at P137,570.68 and P167,674.63 for the two lots. The Provincial Agrarian Reform Adjudication Board (PARAB) affirmed LBP’s recommended amounts in a Resolution dated April 15, 2002.
Respondents filed a complaint in the Regional Trial Court (RTC), Branch 34, Iloilo City, for judicial determination of just compensation on May 10, 2002 (amended September 19, 2003). On September 28, 2007 the RTC, sitting as special agrarian court, departed from any particular formula and, after considering the Section 17 factors of R.A. No. 6657 and other indicia, fixed just compensation at P605,291.91 plus 12% interest per annum from December 1, 2001; it also noted entitlement to a 5% incentive under Section 19 of R.A. No. 6657. The RTC denied LBP’s motion for reconsideration on November 21, 2007.
LBP appealed to the Court of Appeals (CA) by Petition for Review, arguing primarily that the RTC violated the valuation formula in DAR A.O. No. 5, s. 1998 (which operationalizes Section 17, R.A. No. 6657) and that interest awarded was improper. In its March 15, 2013 Decision (CA-G.R. SP No. 03197), the CA affirmed the RTC “with modification”: it increased the just compensation to P611,445.41 but deleted the 12% interest award. LBP’s partial motion for reconsideration was denied by the CA in a June 17, 2014 Resolution.
LBP filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court seeking annulment of the CA Decision and Resolution. The Supreme Court issued the present decision authored by Justice Gaerlan.
Issues:
- Did the Court of Appeals err in affirming with modification the RTC decision fixing just compensation for the subject parcels?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)