Case Digest (G.R. No. 172352)
Facts:
Land Bank of the Philippines v. Alfredo Hababag, Sr., G.R. No. 172352 (consolidated with G.R. Nos. 172387-88), June 08, 2016, Supreme Court Special First Division, Perlas-Bernabe, J., writing for the Court.Petitioner Land Bank of the Philippines (LBP) filed a Motion for Reconsideration (and, in the alternative, a Motion for Clarification) of the Court's September 16, 2015 Decision, which itself had affirmed the Court of Appeals' November 15, 2005 Decision in CA-G.R. SP Nos. 86066 and 86167. Respondents are the Heirs of Alfredo Hababag, Sr. (substituted by his wife Consolacion and their children). The RTC of Sorsogon City, Branch 52 originally tried Civil Case No. 96-6217 and applied the Income Productivity Approach to value the subject 69.3857 hectares, producing a valuation that the CA and the Court later rejected.
The CA fixed just compensation at P2,398,487.24 using the Department of Agrarian Reform (DAR) formula as reflecting the factors in Section 17 of R.A. No. 6657, and imposed legal interest on the unpaid balance. The September 16, 2015 Decision of the Court affirmed that valuation but modified the rate of interest imposed on the unpaid balance, citing developments in the law and monetary policy instruments. The Court noted that LBP had earlier paid provisional compensation of P1,237,850.00, leaving an unpaid principal balance relative to the final just compensation.
In the present postjudgment proceedings, LBP argued that it should be discharged from liability for legal interest (because it promptly deposited the initial valuation and because the difference between its payment and the final award was not "substantial"), and sought clarification on the proper date of taking from which to compute interest. The Court resolved LBP’s Motion for Reconsideration and, alternatively, its Motion for Clarification; it modified the interest computation meth...(Subscriber-Only)
Issues:
- Is the Land Bank of the Philippines liable for legal interest on the unpaid balance of the just compensation?
- From what date must legal interest on the unpaid balance be reckoned (i.e., what is the operative "date of taking") and at what rate should in...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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