Case Digest (G.R. No. 104781)
Facts:
The case involves Spouses Vicente and Leonidas Arenas-Banal, owners of a 19.3422-hectare agricultural land in San Felipe, Basud, Camarines Norte, registered under Transfer Certificate of Title No. T-6296. A portion of this land, specifically 6.2330 hectares (comprising 5.4730 hectares planted with coconut and 0.7600 hectares planted with palay), was compulsorily acquired by the Department of Agrarian Reform (DAR) under Republic Act No. 6657, known as the Comprehensive Agrarian Reform Law (CARL) of 1988. The Land Bank of the Philippines (Landbank), tasked with valuation, valued the land at ₱173,918.55 based on DAR Administrative Orders No. 6 (1992) and No. 11 (1994). The respondents rejected this valuation.
Pursuant to Section 16(d) of R.A. 6657, a summary administrative proceeding was held before the Provincial Agrarian Reform Adjudicator (PARAD), which affirmed Landbank's valuation. The spouses then elevated the matter to the Regional Trial Court (RTC), sitting as a Specia
Case Digest (G.R. No. 104781)
Facts:
- Ownership and Land Description
- Spouses Vicente and Leonidas Banal are registered owners of 19.3422 hectares of agricultural land in San Felipe, Basud, Camarines Norte, registered under Transfer Certificate of Title No. T-6296.
- A 6.2330-hectare portion (5.4730 hectares coconut land, 0.7600 hectare riceland) was compulsorily acquired by the Department of Agrarian Reform (DAR) under Republic Act No. 6657 (Comprehensive Agrarian Reform Law).
- Initial Valuation of the Land
- Land Bank of the Philippines (Landbank), tasked with land valuation under EO No. 405, valued the acquired land at ₱173,918.55 (₱148,675.19 for coconut land and ₱25,243.36 for riceland) using DAR Administrative Orders No. 6 and No. 11 formulas.
- Respondents rejected this valuation, prompting summary administrative proceedings before the Provincial Agrarian Reform Adjudicator (PARAD), which affirmed Landbank’s valuation.
- Judicial Proceedings
- Dissatisfied, respondents filed a petition for just compensation with Regional Trial Court (RTC), Special Agrarian Court Branch 40, Daet, Camarines Norte (Civil Case No. 6806), impleading DAR and Landbank.
- Respondents claimed just compensation of ₱100,000 per hectare, totaling ₱623,000.00.
- During pre-trial (September 23, 1998), parties admitted:
- Land governed by R.A. 6657, as amended.
- Land was distributed to farmer-beneficiaries.
- Landbank deposited provisional compensation based on DAR valuation.
- RTC dispensed with hearing and ordered submission of memoranda.
- RTC Decision
- RTC computed just compensation at ₱657,137.00 (coconut land) plus ₱46,000.00 (riceland), totaling ₱703,137.00.
- Awarded ₱79,732.00 compounded interest.
- RTC used valuation methods from a separate ongoing case (Rodriguez vs. DAR), considering average gross production (AGP), capitalization at 6%, and price per kilo for coconut and riceland, adjusting figures without trial or party consent.
- RTC relied on EO No. 228 and R.A. No. 3844 which deal with rice and corn lands and leasehold relations.
- Appeal
- Landbank appealed to the Court of Appeals (CA-G.R. SP No. 52163), which affirmed RTC decision in toto on March 20, 2000.
- Landbank's motion for reconsideration was denied.
- Petition for review on certiorari filed before the Supreme Court raising errors in valuation and procedure by RTC and CA.
Issues:
- Whether the Court of Appeals erred in affirming the RTC’s valuation of the land, specifically in:
- Dispensing with hearings and deciding without proper examination of evidence.
- Taking judicial notice of facts from a different pending case without parties' knowledge or consent.
- Applying valuation formulas outside the prescribed regulations for lands covered by R.A. 6657.
- Granting compounded interest under DAR Administrative Order No. 13, Series of 1994, when it does not apply to such lands.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)