Title
Land Bank of the Philippines vs. Department of Agrarian Reform Adjudication Board
Case
G.R. No. 183279
Decision Date
Jan 25, 2010
The Supreme Court grants the Adaza family execution pending appeal for just compensation regarding their land under the Comprehensive Agrarian Reform Program, favoring them against the Land Bank of the Philippines and the Department of Agrarian Reform Adjudication Board.
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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 concerns a 359-hectare tract of land 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 the land for compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP) as per Republic Act No. 6657.
  • The LBP initially valued the land at PhP 786,654.46, which the Adazas deemed unreasonably low.
  • The DAR ordered the LBP to deposit this amount, allowing the Adazas to access it while retaining the right to contest the valuation.
  • In December 1992, the DAR subdivided the property and distributed it to beneficiaries.
  • Following a summary administrative hearing, the Provincial Agrarian Reform Adjudicator (PARAD) revalued the land at PhP 3,426,153.80.
  • The Adazas appealed to the DARAB and filed a Motion to Withdraw Amended Valuation on August 9, 2005, seeking the release of the difference between the initial and amended valuations.
  • The LBP contested the motion, arguing the amended valuation was not approved by the DAR.
  • On January 2, 2006, the DARAB granted the motion, allowing the Adazas to withdraw the amount pending appeal.
  • The LBP's motion for reconsideration was denied, leading to a petition for certiorari before the Court of Appeals, which affirmed the DARAB's decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the petition of the LBP is without merit.
  • The Court affirmed the orders of the DARAB, allowing the Adazas to withdraw the recomputed valuation amount pending the final determination of just compensation.

Ratio:

  • The Court emphasized that the amount of PhP 3,426,153.80 sought by the Adazas was based on the LBP's own re-evaluation under Executive Order No. 405, which mandates the LBP to determine land valuation for CARP properties.
  • The LBP had requested the PARAD to adopt this new valuation, acknowledging its validity.
  • The Adazas had been deprived of their land since 1992 and had only received the initial, significantly lower valuation.
  • The principle of just compensation necessitates timely payment to landowners for expropriated property.
  • The LBP's concern about potential financial loss to the government was deemed speculative, as the DARAB found the risk of the amended valuation exceeding the just compensable value to be remote.
  • The Court reiterated that landowners have the right to withdraw amounts deposited for their land pending final resolution of compensation disputes, regardless of whether these amounts are provisional or final.
  • The DARAB's decision to allow execution pending appeal was justified due to the long delay the Adazas experienced in receiving just compensation, affirming the need for prompt payment to prevent further injustice.

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