Case Digest (G.R. No. 140160)
Facts:
Land Bank of the Philippines v. Feliciano F. Wycoco, G.R. Nos. 140160 and 146733, January 13, 2004, Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.Feliciano F. Wycoco was the registered owner of a 94.1690‑hectare unirrigated rice land in Licab, Nueva Ecija (TCT No. NT‑206422). He submitted a voluntary offer to sell the property to the Department of Agrarian Reform (DAR) under the Comprehensive Agrarian Reform Program; the Land Bank of the Philippines (LBP) performed valuation duties pursuant to Executive Order No. 405. After several adjustments, DAR/LBP issued notices proposing acquisition of 84.5690 hectares at various stated amounts; Wycoco rejected the offers. DAR indorsed the matter to the DAR Adjudication Board (DARAB) and LBP opened a trust account in Wycoco’s name; the land was meanwhile distributed to farmer‑beneficiaries. The DARAB docketed the administrative proceeding as VOS Case No. 232 NE 93.
On April 13, 1993, rather than pursue the DARAB summary proceeding, Wycoco filed an action for determination of just compensation in the Regional Trial Court (RTC), Cabanatuan City, Branch 23, acting as a Special Agrarian Court (Agrarian Case No. 91 (AF)), impleading DAR and LBP. He also informed DARAB of the court action; DARAB then dismissed the administrative VOS proceeding on March 9, 1994, to give way to the court determination. At pre‑trial the RTC limited the dispute to the determination of just compensation and required simultaneous memoranda.
Wycoco offered limited documentary evidence (the TCT, notice of land valuation, and his rejection letter). DAR and LBP presented their Land Valuation Worksheets. On November 14, 1995, the RTC rendered judgment in favor of Wycoco, fixing compensation at P142,500 per hectare (totaling approximately P13.4 million) and awarding substantial “unrealized profits” plus legal interest; the RTC later issued an order of execution.
DAR and LBP separately sought relief from the Court of Appeals. DAR’s petition (CA‑G.R. No. SP No. 39234) was dismissed on May 29, 1997 and became final on June 26, 1997; that circumstance prompted Wycoco to file a mandamus petition in this Court (G.R. No. 146733) seeking execution of the RTC decision and the inhibition of Judge Rodrigo S. Caspillo. LBP’s petition (CA‑G.R. No. SP No. 39913) was dismissed on February 9, 1999; the Court of Appe...(Subscriber-Only)
Issues:
- Did the Regional Trial Court, acting as Special Agrarian Court, validly acquire jurisdiction to determine just compensation?
- If jurisdiction was proper, was the RTC’s valuation of the land supported by substantial evidence?
- Can Wycoco compel the DAR to acquire the entire property offered in the voluntary offer to sell?
- Were the RTC’s awards of interest and “un...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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