Case Digest (G.R. No. 172551) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Land Bank of the Philippines v. Yatco Agricultural Enterprises, decided on January 15, 2014, petitioner Land Bank of the Philippines (LBP) sought judicial review of the Court of Appeals’ decision affirming the Regional Trial Court–Special Agrarian Court (RTC-SAC) determination of just compensation in Agrarian Case No. SP-064(02). Respondent Yatco Agricultural Enterprises owned a 27.5730-hectare agricultural parcel in Barangay Mabato, Calamba, Laguna, covered by TCT No. T-49465. On April 30, 1999, the land was placed under the Comprehensive Agrarian Reform Program (CARP) pursuant to Executive Order No. 405. LBP, as mandated, valued the property at ₱1,126,132.89 but respondent disputed this before the Department of Agrarian Reform Provincial Adjudicator (PARAD), which applied the MV × 2 formula under DAR AO 5-98 and fixed compensation at ₱16,543,800.00. LBP then filed a petition in the RTC-SAC, which—without applying Section 17 factors of Republic Act No. 6657 or the DAR formul... Case Digest (G.R. No. 172551) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Yatco Agricultural Enterprises (Yatco) owned a 27.5730-hectare parcel of agricultural land in Barangay Mabato, Calamba, Laguna, covered by TCT No. T-49465.
- Land Bank of the Philippines (LBP), under E.O. No. 405, initially valued the property at ₱1,126,132.89.
- Administrative Proceedings
- Yatco found LBP’s valuation unacceptable and elevated the dispute to the DAR Provincial Agrarian Reform Adjudicator (PARAD), which set just compensation at ₱16,543,800.00 by applying “MV × 2” to the tax-declaration market value.
- LBP did not seek reconsideration before PARAD but filed a petition for judicial determination of just compensation with the Regional Trial Court, Branch 30 (RTC-SAC) in San Pablo City.
- Judicial Proceedings
- RTC-SAC adopted valuations from two prior civil cases involving NAPOCOR easement acquisitions (Branch 36 in Civil Case No. 2259-95-C fixed ₱20.00/sqm; Branch 35 in Civil Case No. 2326-96-C adopted that same rate) and set just compensation at ₱200.00/sqm.
- LBP’s motion for reconsideration was denied; it appealed to the Court of Appeals (CA), which affirmed the RTC-SAC. LBP filed a Rule 45 petition for review on certiorari with the Supreme Court.
Issues:
- Whether the issue raised by LBP—namely, that RTC-SAC erred in relying solely on prior civil-case valuations—is a pure question of law subject to Rule 45 review.
- Whether the RTC-SAC’s determination of just compensation based exclusively on NAPOCOR easement valuations complied with Section 17 of R.A. No. 6657 and DAR AO 5-98.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)