Title
Land Bank of the Philippines vs. Hababag, Sr.
Case
G.R. No. 172352
Decision Date
Jun 8, 2016
The Land Bank of the Philippines is required to pay legal interest on the unpaid balance of just compensation in a case involving land valuation, with the Court affirming the use of the Department of Agrarian Reform formula for valuation and clarifying the date of taking for the computation of legal interest.
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Case Digest (G.R. No. 172352)

Facts:

  • The case involves the petitioner, Land Bank of the Philippines (LBP), and respondents Alfredo Hababag, Sr., his wife Consolacion, and their children.
  • The Supreme Court's decision was rendered on June 8, 2016.
  • The dispute centers on just compensation for 69.3857 hectares of land expropriated for agrarian reform.
  • The Regional Trial Court (RTC) initially set compensation at P1,237,850.00 using the Income Productivity Approach.
  • The Court of Appeals (CA) recalculated the compensation to P2,398,487.24 based on the Department of Agrarian Reform's formula under Republic Act No. 6657.
  • The CA ordered LBP to pay legal interest on the unpaid balance.
  • LBP filed a motion for reconsideration, contesting the legal interest and seeking clarification on the date of taking for interest computation.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied LBP's Motion for Reconsideration, affirming the imposition of legal interest.
  • Legal interest accrues at twelve percent (12%) per annum from the date of taking until June 30, 2013, and at six percent (6%) per annum thereafter until full payment.
  • LBP was ...(Unlock)

Ratio:

  • The Court found LBP's objections to the interest imposition to be without merit, emphasizing the law's requirement for full payment of just compensation.
  • The principal amount must reflect the actual value of the expropriated land, and any unpaid balance justifies accruing legal interest.
  • Citing Apo Fruits Corporation vs. LBP, the Court reiterated that partial payments do not exempt LBP from paying interest on any outstanding balanc...continue reading

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