Case Digest (G.R. No. 166259)
Facts:
Land Bank of the Philippines v. Honeycomb Farms Corporation, G.R. No. 166259, November 12, 2012, the Supreme Court Second Division, Brion, J., writing for the Court. The petition was filed under Rule 45 of the Rules of Court.
Petitioner Land Bank of the Philippines (LBP) is the government financial institution charged under the agrarian reform law with initially determining land valuation; respondent Honeycomb Farms Corporation (HFC) was the registered owner of a 29.0966-hectare parcel (TCT No. T-2550) in Curvada, Cataingan, Masbate that it voluntarily offered to the Department of Agrarian Reform (DAR) for coverage under Republic Act No. 6657 (Comprehensive Agrarian Reform Law).
On February 5, 1988, HFC offered the land to DAR for P581,932.00 (P20,000/ha). DAR and LBP identified an acquirable area of 27.5871 hectares (1.5095 hectares excluded). LBP, applying guidelines in DAR Administrative Order No. 6, series of 1992 (as amended by AO No. 11, s.1994), fixed valuation at P165,739.44 and served a Notice of Valuation, which HFC rejected.
HFC then filed a petition with the DAR Adjudication Board (DARAB) for summary administrative determination (claiming P25,000/ha or P725,000 aggregate). While DARAB proceedings were pending, HFC also filed a Complaint for Determination and Payment of Just Compensation with the Regional Trial Court (RTC) of Masbate, Branch 48, acting as a Special Agrarian Court (SAC), alleging unreasonable delay by DAR and seeking P725,000 plus 10% attorney’s fees. LBP moved that the SAC lacked jurisdiction and that HFC had not exhausted administrative remedies.
On May 14, 1998, DARAB issued a decision affirming LBP’s valuation of P165,739.44 and dismissed HFC’s administrative petition for lack of jurisdiction. The RTC (SAC) nevertheless rendered judgment on July 27, 2000, fixing just compensation at P931,109.20 (the court’s valuation at P32,000/ha for the acquired area and consequential damages for the excluded portion) and awarding attorney’s fees of 10% of the total just compensation; the RTC relied in part on judicial notice of the land’s roadside location and proximity to a commercial district.
Both parties appealed to the Court of Appeals (CA). The CA’s January 28, 2004 decision reversed the RTC and dismissed HFC’s complaint for failure to exhaust administrative remedies under Section 16 of RA 6657. On LBP’s motion for reconsideration, with a copy of the DARAB decision attached, the CA issued an Amended Decision dated September 16, 2004 reinstating the RTC judgment but deleting attorney’s fees; a subsequent CA Resolution was dated November 25, 2004.
LBP then filed the present petition for review on certiorari before the Supreme Court, challenging the CA’s Amended Decision insofar as it (1) allowed the SAC to exercise jurisdiction despite the pending DARAB proceedings, (2) failed to dismiss the complaint for non-exhaustion and forum shopping, and (3) upheld the SAC’s valuation instead of re...(Pro-only)
Issues:
- Did the SAC have jurisdiction to entertain HFC’s petition for determination of just compensation despite the pendency of the DARAB proceedings?
- Did HFC commit forum shopping or fail to exhaust administrative remedies by filing with the SAC while DARAB proceedings were pending?
- Was the CA correct in affirming the SAC’s valuation, or must the SAC apply the factors in Section 17 of RA 6657 and the DAR formula in DAR Administrative Order No. 6, series of 1992, as amended by AO No. 11, s.1994, when determining just compensation?
- Could the SAC properly take judicial notice that a portion of the land was commercial in...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)