Case Digest (G.R. No. 164876)
Facts:
Land Bank of the Philippines v. Leonila P. Celada, G.R. No. 164876, January 23, 2006, the Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.Respondent Leonila P. Celada owned 22.3167 hectares of agricultural land in Calatrava, Carmen, Bohol (TCT No. 16436). In 1998 the Department of Agrarian Reform (DAR) identified 14.1939 hectares of that holding as suitable for compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP) and referred the matter to petitioner Land Bank of the Philippines (LBP) for field investigation and valuation. LBP valued the subject portion at P2.1105517 per square meter, for an aggregate of P299,569.61; the DAR offered that amount to Celada, who rejected it. On August 27, 1999 LBP nonetheless deposited that sum in respondent’s name in cash and bonds.
Pursuant to Section 16(d) of R.A. No. 6657, the case was lodged with the DAR Adjudication Board (DARAB), Region VII (docketed DARAB Case No. VII-4767-B-990). While the DARAB proceeding was pending, Celada filed a petition for judicial determination of just compensation before the Regional Trial Court (RTC), Tagbilaran City, Branch 3, sitting as a Special Agrarian Court (SAC) — Civil Case No. 6462 — alleging that the land’s market value was at least P150,000 per hectare (she cited a mortgage, reported local prices, cultivation and productivity). LBP answered asserting non-exhaustion of administrative remedies and forum-shopping; DAR and the Municipal Agrarian Reform Officer pleaded that determination of just compensation was for LBP and that they were nominal parties.
The DARAB Provincial Adjudicator (PARAD) affirmed LBP’s valuation on April 12, 2000; Celada failed to appear in that administrative hearing. The SAC denied LBP’s affirmative defense that administrative remedies must first be exhausted and proceeded to trial. On March 1, 2003 the SAC fixed compensation at P2.50 per square meter (P354,847.50), awarded 12% legal interest from taking, P10,000 attorney’s fees, incidental expenses of P5,000 and costs. LBP appealed to the Court of Appeals, which dismissed the appeal outright on procedural defects: absence of an affidavit of service, counsel’s omission of his Roll of Attorneys number, and failure to attach material portions of the records. The CA denied LBP’s motion for reconsideration.
LBP filed a petition for review under Rule 45 to the Supreme Court, assigning (a) that the CA rigidly applied procedural rules at the expense of substantial justice; (b) that the SAC wrongly assumed jurisdiction despite ongoing DARAB proceedings; (c) that the SAC erred substantively by setting aside LBP’s valuation ba...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in dismissing LBP’s appeal on technical procedural grounds rather than resolving the appeal on its merits?
- Was the SAC precluded from adjudicating Celada’s petition for determination of just compensation while administrative proceedings before the DARAB were pending (i.e., was there a requirement to exhaust administrative remedies)?
- Did the SAC err substantively in setting aside LBP’s valuation and in awa...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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