Title
Land Bank of the Philippines vs. Department of Agrarian Reform Adjudication Board
Case
G.R. No. 183279
Decision Date
Jan 25, 2010
Heirs of Adaza contested DAR's land valuation under CARP; SC upheld DARAB's order to release revalued compensation, emphasizing timely payment as essential to just compensation.
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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:

  1. 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.

  2. 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.

  3. 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.

  4. Rights of Landowners
    Landowners are entitled to withdraw amounts deposited on their behalf, whether provisional or final, pending the final determination of just compensation.


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