Case Digest (G.R. No. 170685) Core Legal Reasoning Model
Facts:
This case revolves around a dispute between the Land Bank of the Philippines (LBP) as the petitioner and Enrique Livioco as the respondent. Livioco, the owner of a 30.6329-hectare sugarland located in Dapdap, Mabalacat, Pampanga, offered his land for acquisition under the Comprehensive Agrarian Reform Program (CARP) in 1987 or 1988, setting a price of P30.00 per square meter, amounting to a total of P9,189,870.00. The Department of Agrarian Reform (DAR) referred his offer to LBP for valuation, which resulted in a lower compensation valuation of P3.21 per square meter or P827,943.48 for 26 hectares, a decision Livioco contested two years later due to the perceived appreciation of his land's value. Over time, LBP took possession of Livioco's property, distributing Certificates of Land Ownership Award (CLOAs) to 26 farmer-beneficiaries in 1994. Livioco's attempts to regain his property through various means, including filing multiple legal complaints, were unsuccessful
Case Digest (G.R. No. 170685) Expanded Legal Reasoning Model
Facts:
Ownership and Offer for Sale
Respondent Enrique Livioco owned 30.6329 hectares of sugarcane land in Mabalacat, Pampanga. Between 1987 and 1988, he voluntarily offered the land for sale to the Department of Agrarian Reform (DAR) under the Comprehensive Agrarian Reform Program (CARP) at P30.00 per square meter, totaling P9,189,870.00.
Land Valuation by LBP
The Land Bank of the Philippines (LBP), tasked with valuing the land under CARP, set the price at P3.21 per square meter, totaling P827,943.48 for 26 hectares. Livioco was informed of this valuation but did not act on it.
Compulsory Acquisition and Issuance of CLOAs
In 1991, LBP certified the earmarked amount for compensation. By 1994, DAR awarded Certificates of Land Ownership Award (CLOAs) to 26 farmer-beneficiaries. Livioco filed complaints to cancel the CLOAs and recover his property, but these were dismissed.
Amended Valuation and Judicial Determination
LBP later amended the valuation, reducing the acquired area to 24.2088 hectares, valued at P770,904.54. Livioco, unwilling to accept the valuation, filed a petition for judicial determination of just compensation in 2001, claiming the land’s value had increased due to its potential for residential use.
Evidence Presented
Livioco presented certifications from various government agencies asserting the land's suitability for residential use and zonal values ranging from P150 to P200 per square meter. He also submitted a sworn valuation of P700 per square meter and testimonies from appraisers supporting higher valuations.
Trial Court Decision
The Regional Trial Court (RTC) ruled in favor of Livioco, valuing the land at P700 per square meter, totaling P16,946,160.00. The Court of Appeals (CA) affirmed this decision, citing preponderance of evidence supporting Livioco’s valuation.
Issues:
The main issue was whether the compensation for Livioco’s property was determined in accordance with law, specifically Section 17 of RA 6657, which outlines factors for determining just compensation.
Ruling:
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Ratio:
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