Case Digest (G.R. No. 79690-707)
Facts:
The case involves a petition for review on certiorari filed by the Land Bank of the Philippines (LBP) against Severino Listana. The controversy arose from the determination of just compensation for a piece of agricultural land. Severino Listana owned a 246.0561-hectare parcel of land in Inlagadian, Casiguran, Sorsogon, covered by Transfer Certificate of Title No. T-20193. Under the Comprehensive Agrarian Reform Program (CARP), the land was voluntarily offered for sale to the government. The LBP valued the land at P5,871,689.03 for a portion measuring 240.9066 hectares, but Listana rejected this valuation. Consequently, a summary proceeding was conducted by the Department of Agrarian Reform (DAR), resulting in a decision dated October 14, 1998, by DAR Provincial Adjudicator Manuel M. Capellan, which fixed just compensation at P10,956,963.25. LBP received this decision on October 27, 1998.
Shortly after, on September 6, 1999, LBP sought determination of just compensation through
Case Digest (G.R. No. 79690-707)
Facts:
The issue arose from the acquisition of a 246.0561‐hectare land by the government under the Comprehensive Agrarian Reform Program (CARP). The owner, Severino Listana, voluntarily offered around 240.9066 hectares for sale to the government. The Land Bank of the Philippines (LBP), acting as the petitioner, initially valued the land at an amount that the owner rejected. Subsequently, the Department of Agrarian Reform (DAR) conducted a summary administrative proceeding and, on May 14, 1998, fixed just compensation for the entire 240.9066 hectares at over P10.9 million. However, a part of the land (151.1419 hectares) had already been accepted by the owner and transferred to the government through a deed executed on May 7, 1996, with corresponding cash and bond payments received by LBP. LBP, challenging the DAR’s valuation especially on the remaining 89.1419 hectares—alleging that the computation did not follow the formula under Section 17 of R.A. No. 6657 and the amended DAR administrative orders—filed a petition for judicial determination of just compensation before a Special Agrarian Court (RTC). The owner, meanwhile, argued that his prior acceptance of the valuation for the 151.1419-hectare portion constituted a binding contract, invoking res judicata, and maintained that the necessitated remedy was already exhausted. Crucially, LBP filed its petition beyond the 15‑day period prescribed by the DARAB Rules, and its subsequent filings and motions (including for reconsideration) did not cure this tardiness.Issues:
- Whether the petition for judicial determination of just compensation, filed more than 100 days after notice of the DAR’s decision, can be accepted despite being beyond the 15‑day reglementary period set forth in the DARAB Rules of Procedure.
- Whether the alleged errors in the DAR’s administrative valuation—specifically the inclusion of the 151.1419 hectares already accepted and the non‐application of the prescribed computation formula for the remaining land—warrant a relaxation of the procedural rules in view of the public interest implicated by a potential overpayment.
- Whether the owner’s acceptance of part of the valuation should operate as a consummated contract, thereby invoking the doctrine of res judicata to bar the petition.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)