Case Digest (G.R. No. 172551)
Case Digest (G.R. No. 172551)
Facts:
Land Bank of the Philippines v. Yatco Agricultural Enterprises, G.R. No. 172551, January 15, 2014, Supreme Court Second Division, Brion, J., writing for the Court.Petitioner Land Bank of the Philippines (LBP) sought review of the Court of Appeals’ decision dated January 26, 2006 and its resolution of May 3, 2006 in CA‑G.R. SP No. 87530, which had affirmed the Regional Trial Court, Branch 30, San Pablo City acting as Special Agrarian Court (RTC‑SAC)’s decision in Agrarian Case No. SP‑064(02) dated July 30, 2004. Respondent Yatco Agricultural Enterprises (Yatco) was the registered owner of a 27.5730‑hectare agricultural parcel in Calamba, Laguna covered by TCT No. T‑49465, placed under CARP by Second Notice of Coverage dated April 30, 1999.
Pursuant to E.O. No. 405, LBP initially valued the property at P1,126,132.89. Yatco rejected that valuation and filed summary administrative proceedings before the DAR Provincial Agrarian Reform Adjudicator (PARAD), which computed just compensation at P16,543,800.00 using the tax declaration market value and applying the DAR formula MV x 2. LBP did not file reconsideration with the PARAD but instead filed a petition for judicial determination of just compensation in the RTC‑SAC on February 6, 2002.
The RTC‑SAC fixed just compensation at P200.00 per square meter, adopting valuation determinations earlier made by RTC Calamba Branch 36 (Civil Case No. 2259‑95‑C) and Branch 35 (Civil Case No. 2326‑96‑C). The RTC‑SAC found LBP’s valuation procedure and evidence inadequate and did not independently apply the factors in Section 17 of R.A. No. 6657 or DAR AO 5‑98 in a documented computation. LBP’s motion for reconsideration before the RTC‑SAC was denied; the Court of Appeals dismissed LBP’s appeal, holding that the civil‑case valuations were persuasive and that the determination of just compensation is essentially a judicial function. LBP filed the present Rule 45 petition for review on certiorari with the Supreme Court.
Issues:
- Does the petition for review on certiorari under Rule 45 raise a question of law (and thus is properly before the Court)?
- Was the RTC‑SAC’s determination of just compensation for the subject property proper under R.A. No. 6657 and DAR AO 5‑98?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)