Case Digest (G.R. No. 118712)
Facts:
In Land Bank of the Philippines (LBP) and the Department of Agrarian Reform (DAR) v. Court of Appeals, petitions for certiorari under G.R. Nos. 118712 and 118745 arose when LBP, as the depository designated by DAR under Republic Act No. 6657 (Comprehensive Agrarian Reform Law), opened trust accounts instead of depositing compensation “in cash” or in “LBP bonds” as required by Section 16(e) of RA 6657. The respondents, headed by Pedro L. Yap and including the Heirs of Emiliano F. Santiago and the Agricultural Management & Development Corporation, rejected the initial valuation, prompting LBP to withhold immediate release of the funds and place the amounts in trust pending final adjudication of just compensation. The Court of Appeals ruled that the trust accounts sufficed as deposit and allowed partial withdrawal by the rejecting landowners. Upon denial of their petitions for review on certiorari by this Court on October 6, 1995, petitioners filed motions for reconsideration, insiCase Digest (G.R. No. 118712)
Facts:
- Background of the case
- The Department of Agrarian Reform (DAR) and the Land Bank of the Philippines (LBP) sought certiorari relief from this Court after the Court of Appeals denied their petitions (G.R. Nos. 118712 & 118.745).
- On October 6, 1995, this Court denied both petitions, prompting DAR and LBP to file separate motions for reconsideration.
- Petitioners’ contentions
- DAR and LBP argued that opening trust accounts in favor of rejecting landowners constituted “deposit” under Section 16(e) of Republic Act No. 6657, thus satisfying the statutory requirement for payment of compensation.
- They further maintained that the deposited funds should remain in trust—unwithdrawable by landowners—pending final judicial valuation, to protect the Government against potential legislative or administrative changes, force majeure events, or program abandonment.
- Statutory provision in issue
- Section 16(e) of RA 6657 requires that, upon rejection by a landowner, compensation “in cash or in LBP bonds” be deposited with an accessible bank designated by DAR before taking possession.
- Petitioners’ administrative rules and LBP Executive Order No. 003 (January 19, 1993) permitted partial withdrawal (50%) from such trust accounts.
Issues:
- Whether the opening of trust accounts satisfies the “deposit in cash or in LBP bonds” requirement of Section 16(e) of RA 6657.
- Whether rejecting landowners may immediately withdraw the full amount of the deposited compensation pending final valuation of their property.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)