Case Digest (G.R. No. 183279)
Facts:
The case involves the Land Bank of the Philippines (LBP) as the petitioner and the Department of Agrarian Reform Adjudication Board (DARAB) along with the heirs of Vicente, Romeo, and Cesar Adaza, represented by Russel Adaza, as respondents. The dispute centers around a 359-hectare tract of land located in Patagan, Manukan, Zamboanga del Norte, covered by Transfer Certificate of Title No. T-42963. In August 1991, the Department of Agrarian Reform (DAR) identified a 278.4092-hectare portion of this land for compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP) as mandated by Republic Act No. 6657. The LBP assigned an initial valuation of PhP 786,654.46 for the land, which the Adazas rejected as unreasonably low. Consequently, the DAR ordered the LBP to deposit this amount, allowing the Adazas to access it while retaining their right to contest the valuation.
In December 1992, the DAR subdivided the property and distributed it to beneficiaries. Followi...
Case Digest (G.R. No. 183279)
Facts:
Ownership and Land Coverage
Private respondents, the heirs of Vicente, Romeo, and Cesar Adaza, represented by Russel Adaza, owned a 359-hectare land in Patagan, Manukan, Zamboanga del Norte, covered by Transfer Certificate of Title No. T-42963. The Department of Agrarian Reform (DAR) identified 278.4092 hectares as suitable for compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP) pursuant to Republic Act No. 6657 (CARP Law).
Initial Valuation and Rejection
In August 1991, the DAR sent a notice of coverage, and the Land Bank of the Philippines (LBP) valued the land at PhP 786,654.46. The Adazas rejected this offer, deeming it unreasonably low. The DAR deposited the amount, which the Adazas withdrew without prejudice to their right to a final determination of just compensation. The land was subsequently subdivided and distributed to beneficiaries in December 1992.
Revaluation and Appeal
In 2003, the Provincial Agrarian Reform Adjudicator (PARAD) ordered the LBP to revalue the land, resulting in a new valuation of PhP 3,426,153.80. The Adazas appealed this amount to the DARAB, seeking the release of the incremental difference. The DARAB granted their motion, ordering the release of the amount pending appeal.
Issue:
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Ruling:
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Ratio:
Just Compensation
Just compensation under the CARP Law requires not only the correct valuation but also timely payment. The landowners cannot be left deprived of their property without receiving fair and timely compensation.LBP's Role in Valuation
Under Executive Order No. 405, the LBP is primarily responsible for determining land valuation. The DARAB affirmed the LBP's revalued amount, effectively approving it.Execution Pending Appeal
The DARAB may allow execution pending appeal upon meritorious grounds. In this case, the Adazas' prolonged deprivation of their property justified the release of the revalued amount without requiring a bond.Rights of Landowners
Landowners are entitled to withdraw amounts deposited on their behalf, whether provisional or final, pending the final determination of just compensation.