Case Digest (G.R. No. 169903)
Facts:
Land Bank of the Philippines v. Honeycomb Farms Corporation, G.R. No. 169903, April 29, 2013, Supreme Court Second Division, Brion, J., writing for the Court.Honeycomb Farms Corporation was the registered owner of two agricultural parcels in Cataingan, Masbate (TCT No. T-2872 — 240.8874 ha; TCT No. T-2549 — 254.25 ha). On February 5, 1988 Honeycomb Farms voluntarily offered a total of 495.1374 hectares to the Department of Agrarian Reform (DAR) under RA 6657 for P10,480,000.00; the government chose to acquire 486.0907 hectares. Pursuant to its administrative role, the Land Bank of the Philippines (LBP) fixed preliminary valuations using DAR administrative guidelines; the values were rejected by Honeycomb Farms and the matter was referred to the DAR Adjudication Board, which set a higher market value that Honeycomb Farms still rejected.
On July 4, 1994 Honeycomb Farms filed Special Civil Case No. 4323 in the Regional Trial Court (RTC) of Masbate, Branch 48, acting as a Special Agrarian Court (SAC), seeking determination and payment of just compensation (originally P12,440,000, later amended to P20,000,000). The RTC convened a Board of Commissioners which failed to agree on valuation; the RTC then took judicial notice that about 10 hectares were commercial and independently set compensation at P100,000/ha for that portion and P32,000/ha for the remainder, arriving at a total it described in the judgment as P25,232,000 (July 6, 1999), and awarded attorneys’ fees of 10% of the total just compensation.
Both parties appealed. The Court of Appeals (CA) in a March 31, 2005 decision affirmed with modification: it corrected the total to P16,232,000 and deleted the award of attorneys’ fees, holding that courts are not strictly bound by the DAR factors and that LBP’s administrative valuation was confiscatory. LBP filed a petition for review in the Supreme Court assailing the CA’s rejection of the DAR administrative formula and the RTC/CA valuations; Honeycomb Farms contended...(Pro-only)
Issues:
- Must the RTC, acting as a Special Agrarian Court, apply the formula set forth in the applicable DAR Administrative Orders in determining just compensation under RA 6657?
- Was the RTC permitted to take judicial notice that a 10-hectare portion of the property was commercial without announcing such intent and allowing the parties to be heard?
- Is the LBP’s opening of a trust account in the landowner’s name an acceptable mode of payment under RA 6657, and if not, is the trust account to be co...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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