Title
Land Bank of the Philippines vs. Imperial
Case
G.R. No. 157753
Decision Date
Feb 12, 2007
The Supreme Court affirmed that a 6% annual interest must be included in just compensation calculations, deeming certain areas compensable while excluding portions retained by the owner-cultivator.
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Case Digest (G.R. No. 157753)

Facts:

  • The case involves the Land Bank of the Philippines (petitioner) and Juan H. Imperial (respondent).
  • Imperial owned five parcels of land totaling 156.1000 hectares in Barangay Pawa, Manito, Albay.
  • The lands were placed under the Operation Land Transfer (OLT) program as part of the Land Reform Program under Presidential Decree No. 27 and Executive Order No. 228.
  • On October 21, 1972, the lands were distributed to farmer beneficiaries.
  • On July 20, 1994, Imperial filed a complaint against the Land Bank, the Department of Agrarian Reform (DAR), and the farmer beneficiaries for just compensation, docketed as Agrarian Case No. 94-01.
  • A commission assessed the lands' valuation, concluding on June 21, 1996, that the lands were not first-class riceland, valuing them at P2,012.50 per hectare.
  • Imperial objected to this valuation, leading to further evidence being gathered.
  • An amended complaint was filed on January 29, 1997, addressing discrepancies in land area.
  • A second report on August 27, 1997, adjusted the compensable area to 151.7168 hectares, with new valuations of P8,050 for unirrigated land and P32,200 for irrigated land, totaling P1,088,251.57.
  • On August 4, 2000, the trial court fixed just compensation at P2,185,241.50, declaring 4.3832 hectares as non-compensable.
  • The Court of Appeals set aside this ruling on November 23, 2001, remanding the case for reevaluation and imposing a 6% annual interest on compensation.
  • The Land Bank's motion for reconsideration was denied on March 21, 2003, leading to the current petition.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition for lack of merit and affirmed the Court of Appeals' decision with modifications.
  • Just compensation should include a 12% annual interest for the delay in payment.
  • Areas used as feeder road, right of w...(Unlock)

Ratio:

  • The Supreme Court emphasized that just compensation must reflect both the correct amount and timely payment.
  • The appellate court's imposition of a 6% interest for ...continue reading

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