G.R. No. 128557 - Land Bank of the Philippines vs. Court of Appeals

The Government's agrarian reform program under PD 27 and EO 228 aimed to distribute agricultural lands to tenant farmers, depriving landowners of ownership but guaranteeing just compensation.
The landowner, private respondent Jose Pascual, owned three parcels of land in Guttaran, Cagayan:

Parcel 1 (TCT No. 16655): Surveyed area 149,852 sqm, land transferred approx. 102,229 sqm, classified unirrigated lowland rice.
Parcel 2 (TCT No. 16654): Surveyed area 123,043 sqm, land transferred approx. 85,381 sqm, classified cornland.
Parcel 3 (TCT No. 16653): Surveyed area 192,590 sqm, land transferred approx. 161,338 sqm, classified irrigated lowland rice.

The Department of Agrarian Reform (DAR) through its Provincial Agrarian Reform Officer (PARO) applied the valuation rules under EO 228, computing land value based on Average Gross Production (AGP), multiplied by 2.5 and the Government Support Price (GSP) of 1972 (P35 per cavan of palay, P31 per cavan of corn).
PARO recommended AGP values of 25 cavans/ha for unirrigated lowland rice and 10 cavans/ha for cornland in December 1989.
Secretary of Agrarian Reform (SAR) independently valued Parcel 1 using an AGP of 25.66 cavans and fixed the valuation at P22,952.97. The Land Bank of the Philippines (LBP) approved this valuation in February 1991.

Jose Pascual contested the PARO’s valuation, filing a petition before the Department of Agrarian Reform Adjudication Board (DARAB) for annulment of the AGP and valuation recommendation.
Evidence included a 1976 OLT Valuation Form showing higher AGPs (80 cavans/ha for unirrigated rice, 28 for corn, 100 for irrigated rice) and tax declarations supporting higher productivity figures.
PARAD ruled in favor of Pascual in June 1992, adopting the older higher AGP and a 1992 GSP (P300 per cavan palay, P250 per cavan corn), resulting in a total valuation of P1,961,950 for all parcels.
Pascual accepted the PARAD valuation.

After the judgment became final, LBP refused to pay, prompting Pascual to file for writ of execution before PARAD, which was issued in December 1992.
LBP still declined to comply. The DAR Secretary wrote twice in 1994-1995 directing LBP to comply; LBP refused citing:

LBP agreed to pay only if the farmer-beneficiaries concurred and re-executed agreements reflecting the valuation and amortization thereof.

Pascual filed a petition for mandamus in the Court of Appeals compelling LBP to pay.
On July 15, 1996, Court of Appeals issued Writ of Mandamus ordering LBP to pay with 6% compounded interest per Administrative Order No. 13, series of 1994.
LBP’s Motion for Reconsideration was denied on March 11, 1997.
LBP appealed to the Supreme Court, raising issues over jurisdiction, obligation to pay without farmer consent, and applicability of interest.

Whether the Department of Agrarian Reform Adjudication Board (DARAB) has jurisdiction to determine the valuation of lands covered by PD 27 and EO 228.

Whether the Land Bank of the Philippines (LBP) can be compelled to pay the valuation awarded by the DARAB without the consent of the farmer-beneficiaries.

Whether the appellant, LBP, is duty-bound to comply with the DARAB’s valuation and the Writ of Mandamus issued by the Court of Appeals.

Whether the 6% compounded interest imposed by the Court of Appeals under Administrative Order No. 13, s. 1994, applies to the valuation awarded in this case.