Case Digest (G.R. No. 190321)
Facts:
The case involves the Land Bank of the Philippines (LBP) as the petitioner and the heirs of Fernando Alsua, represented by Ramon Alsua, as the respondents. The respondents own coconut lands identified as Lot Nos. 5114 and 5362 located in Lomacao, Guinobatan, Albay, with an aggregate area of 16.7641 hectares. These lands were covered by Transfer Certificate of Title (TCT) Nos. T-10520 and T-10529 respectively, originally in the name of Fernando Alsua. The lands were placed under the Comprehensive Agrarian Reform Program (CARP) through the voluntary offer to sell (VOS) scheme. A field investigation revealed that 6.6435 hectares of Lot No. 5114 and the entire 9.7719 hectares of Lot No. 5362 were fit for acquisition. The LBP received the claim folders in October 1995. Subsequently, the respondents’ certificates of title were cancelled and new titles were issued to the Republic of the Philippines, represented by the Department of Agrarian Reform (DAR). The LBP valued the acquired por...Case Digest (G.R. No. 190321)
Facts:
- Ownership and Subject Lands
- The respondents, Heirs of Fernando Alsua, represented by Ramon Alsua, are owners of coconut lands named Lot Nos. 5114 and 5362.
- These lands are covered by Transfer Certificate of Title (TCT) Nos. T-10520 (6.9922 hectares) and T-10529 (9.7719 hectares), totaling 16.7641 hectares located in Lomacao, Guinobatan, Albay.
- The lands were placed under the Comprehensive Agrarian Reform Program (CARP) via the voluntary offer to sell (VOS) scheme.
- Acquisition and Valuation
- A field investigation by Land Bank of the Philippines (LBP) and representatives from the Department of Agrarian Reform (DAR), Municipal Agrarian Reform Officer (MARO), and Barangay Agrarian Reform Council (BARC)
- Found 6.6435 hectares out of 6.9922 hectares of Lot No. 5114 fit for acquisition
- Entire 9.7719 hectares of Lot No. 5362 were fit for acquisition.
- New titles were issued to the Republic through the DAR:
- TCT No. T-98239 for Lot No. 5362 on June 28, 1996
- TCT No. T-125590 for Lot No. 5114 on February 13, 2001.
- LBP valued the lands at P170,164.48 (Lot 5114) and P455,386.27 (Lot 5362) using the two-factor formula under DAR Administrative Orders No. 6, series of 1992 and No. 11, series of 1994.
- Respondents rejected the compensation offered by DAR.
- Provisional compensation was deposited in respondents' name on June 27, 1996, and released on December 9, 2004.
- Administrative and Judicial Proceedings
- Office of the Provincial Adjudicator fixed just compensation for Lot Nos. 5114 and 5362 at P388,102.37 and P1,036,276.89 respectively.
- LBP moved for reconsideration, denied by the DARAB.
- LBP filed petition for determination of just compensation with RTC, acting as Special Agrarian Court (SAC).
- RTC ordered re-investigation of annual gross production and selling price data for properties for the period preceding June 30, 2009.
- LBP contended RA 9700 and DAR A.O. No. 1, series of 2010 were inapplicable because claim folders were received prior to July 1, 2009.
- RTC denied motion for reconsideration.
- LBP filed Petition for Certiorari and Prohibition with CA, granted for issuance of TRO enjoining RTC from implementing order.
- After 60-day TRO lapse, RTC ruled on merits:
- Fixed just compensation at P660,425.17 (Lot 5114) and P820,256.51 (Lot 5362).
- Used valuation based on presumptive date of taking June 30, 2009, pursuant to DAR A.O. No. 1, series of 2010, using three-factor and two-factor formulas.
- LBP's motion for reconsideration denied; filed Petition for Review before Court of Appeals (CA).
- Court of Appeals Decision
- CA set aside RTC decision dated February 28, 2012 for failure to consider factors enumerated in Section 17 of RA 6657, as amended.
- CA ruled DAR A.O. No. 1, series of 2010 was inapplicable as it only applies to tenanted rice and corn lands.
- CA ordered remand for proper determination of just compensation:
- Valuation at time of taking: June 28, 1996 (Lot 5362) and February 13, 2001 (Lot 5114).
- Use Section 17 of RA 6657 prior to amendment by RA 9700.
- RTC may impose legal interest on just compensation at specified rates.
- CA held RTC not strictly bound by DAR formulae if situations warrant deviation.
- Issue Raised
- Whether CA erred in setting aside RTC Decision for failure to consider Section 17 factors and remanding the case.
- LBP contends it applied correct formula under DAR A.O. No. 5, series of 1998.
- Respondents assert CA correctly applied law and valuation standards.
Issues:
- Did the Court of Appeals err in setting aside the RTC decision and remanding the case for proper determination of just compensation?
- Whether the RTC was correct in using the production data and formulas under RA 9700 and DAR A.O. No. 1, series of 2010, despite the claim folders being received before July 1, 2009?
- Was the Land Bank's valuation compliant with Section 17 of RA 6657, as amended, considering all factors required for computation of just compensation?
- Is the RTC, acting as a Special Agrarian Court, strictly bound by DAR Administrative Orders for valuation formulae in determining just compensation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)