Case Digest (G.R. No. 143276)
Facts:
Landbank of the Philippines v. Spouses Vicente Banal and Leonidas Arenas‑Banal, G.R. No. 143276, July 20, 2004, Supreme Court Third Division, Sandoval‑Gutierrez, J., writing for the Court. The petition arises from the compulsory acquisition under R.A. No. 6657 of a 6.2330‑hectare portion (5.4730 ha coconut; 0.7600 ha palay) of respondents’ 19.3422‑hectare property in Basud, Camarines Norte, title No. T‑6296. Pursuant to DAR procedures, Land Bank of the Philippines (Landbank) valued the acquired portion at P173,918.55 using the formula in DAR Administrative Order No. 6, Series of 1992, as amended by DAR Administrative Order No. 11, Series of 1994; respondents rejected that valuation.A summary administrative proceeding before the Provincial Agrarian Reform Adjudicator (PARAD) affirmed Landbank’s valuation. Respondents then filed in the Regional Trial Court (RTC), Branch 40, Daet (designated a Special Agrarian Court), Civil Case No. 6806, for determination of just compensation; DAR and Landbank were impleaded. They sought P100,000 per hectare (P623,000 total). At pre‑trial the parties admitted (among other things) that the land was covered by R.A. 6657, had been distributed to farmer‑beneficiaries, and that Landbank had deposited provisional compensation.
Instead of conducting an evidentiary hearing, the RTC dispensed with the hearing and ordered memoranda. In its Decision dated February 5, 1999, the RTC computed just compensation at P657,137.00 (coconut) and P46,000.00 (riceland), total P703,137.00, and awarded compounded interest of P79,732.00, basing its computation on average gross production figures and pricing used in another case pending before it (Civil Case No. 6679, Luz Rodriguez v. DAR, et al.) and applying formulas drawn from R.A. No. 3844 and Executive Order No. 228.
Landbank appealed to the Court of Appeals (CA‑G.R. SP No. 52163). On March 20, 2000 the Court of Appeals affirmed the RTC in toto; Landbank’s motion for reconsideration was denied. Landb...(Subscriber-Only)
Issues:
- Did the RTC commit reversible procedural error by dispensing with an evidentiary hearing and taking judicial notice of the contents of another case without giving the parties opportunity to be heard?
- Did the RTC and the Court of Appeals err in applying valuation formulas under Executive Order No. 228 and R.A. No. 3844 instead of the valuation formula prescribed by the DAR Administrative Order No. 6, Series of 1992, as amended by DAR Administrative Order No. 11, Series of 1994, in determining just compensation under R.A. No. 6657?
- Was the award of 6% compounded interest under DAR Admini...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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