Case Digest (G.R. No. 160143)
Facts:
Land Bank of the Philippines v. Benecio Eusebio, Jr., G.R. No. 160143, July 02, 2014, Supreme Court Second Division, Brion, J., writing for the Court.
Petitioner Land Bank of the Philippines (LBP) sought review of the Court of Appeals' August 26, 2002 decision and September 24, 2003 resolution in CA-G.R. CV No. 66022, which affirmed the June 29, 1999 judgment of the Regional Trial Court of Masbate, Branch 48, sitting as a Special Agrarian Court (RTC-SAC) in Special Civil Case No. 4325, awarding just compensation for land taken under the agrarian reform law.
Respondent Benecio Eusebio, Jr. owned a 790.4-hectare parcel (originally titled in Ricardo Tanada) which he purchased in 1980. On February 5, 1988, Eusebio voluntarily offered to sell the entire parcel to the government under R.A. No. 6657 for P19,500,000. The DAR elected to acquire 783.37 hectares and initially offered P2,369,559.64, later increasing the offer to P3,149,718.20; Eusebio rejected these amounts.
On October 1, 1993, the LBP revalued the acquirable portion at P3,927,188.28 pursuant to DAR Administrative Order No. 6, s. 1992 (DAR AO 6-92); Eusebio rejected this. The LBP nonetheless opened a trust account with P3,149,718.20 in favor of Eusebio and Tanada, the DAR took possession, TCT No. T-4562 was cancelled in favor of the Republic, and the lands were distributed to identified farmer-beneficiaries. The DAR Adjudication Board fixed compensation at P4,874,659.89 on January 8, 1994, which Eusebio also rejected.
Eusebio and Tanada filed in the RTC-SAC on July 18, 1994 for determination and payment of just compensation, praying initially for P20,000,000 and later amending to P25,000,000 plus attorneys' fees. The RTC-SAC appointed a Board of Commissioners which conducted an ocular inspection in 1997; party nominees submitted widely divergent valuations (Engr. Hernando Caluag valuing the land at P86,899,000 using market comparables; LBP/DAR nominee Herbert Heath valuing it at P4,081,405.63 using R.A. No. 6657 factors).
In its June 29, 1999 judgment, the RTC-SAC fixed just compensation at P25,000,000 for the entire parcel and ordered the DAR and LBP to pay attorneys' fees of 10% of total compensation. The RTC-SAC rejected party valuations as unconstitutional or confiscatory but did not explain a formulaic basis for its P25,000,000 figure. The RTC-SAC denied motions for reconsideration on October 21, 1999.
Both sides appealed to the Court of Appeals. In an August 26, 2002 decision the CA affirmed the RTC-SAC in toto, holding that (a) compensation is to be fixed as of the time of taking (not the time of filing) and therefore the Caluag market valuation based on later data was unfair, and (b) the DAR/LBP valuation was too low because it ignored relevant market factors; the CA considered the 1988 offer of P19.5M as a floor and deemed the RTC-SAC ...(Subscriber-Only)
Issues:
- Was the RTC-SAC's determination of just compensation at P25,000,000.00 (with 10% attorneys' fees) proper and free from grave abuse of discretion?
- Whether just compensation for land taken under the agrarian reform program is limited by the government's exercise of police power such that it cannot exceed market value.
- Whether the RTC-SAC was bound to consider and apply the factors enumerated in Section 17 of R.A. No. 6657 and the DAR-prescribed formulae (e.g., DAR AO 6-92, as amended) in fixing just compensation, and whether deviation is permissible.
- Whether the LBP's opening of a trust account in favor of Eusebio satisfied the payment/deposit requirements of Section 16(e)...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)