Case Digest (G.R. No. 221060)
Facts:
This case, G.R. No. 221060, involves Marken, Incorporated (petitioner), now known as Aquasalina Incorporated, against respondents Landbank of the Philippines (LBP), the Department of Agrarian Reform (DAR), and the Department of Agrarian Reform Adjudication Board (DARAB). The case’s origins trace back to a Notice of Coverage issued on August 12, 1998, which informed the petitioner that their two parcels of agricultural land in Barangays San Agustin and Bubog Central, Municipality of San Jose, Occidental Mindoro were placed under the Compulsory Acquisition Scheme of the Comprehensive Agrarian Reform Program (CARP) under Republic Act No. 6657. The properties are covered by Transfer Certificate of Title (TCT) Nos. T-13682 and T-13683, with a total area of approximately 511.5 hectares.
In accordance with the CARP provisions, the LBP assessed the value of the properties as totaling P19,530,753.95. Subsequently, DAR requested compensation deposits from LBP, which it ultimately provid
Case Digest (G.R. No. 221060)
Facts:
- Background of the Case
- Marken, Incorporated (now known as Aquasalina Incorporated) is the owner of two parcels of land located in Barangays San Agustin and Bubog Central, Municipality of San Jose, Province of Occidental Mindoro, covered by TCT Nos. T-13682 and T-13683.
- The subject properties have an aggregate area of approximately 411.2680 and 100.2302 hectares, respectively.
- In 1998, a Notice of Coverage and Field Investigation was issued, placing the subject properties under the Compulsory Acquisition Scheme of the Comprehensive Agrarian Reform Program (CARP) pursuant to R.A. No. 6657.
- Valuation and Administrative Proceedings
- The Landbank of the Philippines (LBP) determined the value of the subject properties through valuation inputs and prepared the Memoranda of Valuation, Claim Folder Profile, and Valuation Summaries of Agricultural Land (MOV-CFPVS).
- For TCT No. T-13682, the total valuation was P11,648,130.73.
- For TCT No. T-13683, the total valuation was P7,882,623.22.
- DAR, through its adjudication board (DARAB) in DARAB Case No. JC-IV-0330-OCC-MDO-CO-02, conducted summary administrative proceedings for the fixing of just compensation after petitioner rejected the LBP’s valuation.
- On September 5, 2011, DARAB rendered a Decision adopting the LBP’s valuation as the just compensation due, and on September 13, 2012, DARAB issued a Resolution denying the petitioner’s subsequent motion for reconsideration.
- Cascade of Appeals and Petitioner’s Arguments
- Petitioner (Marken, Inc.) filed a Petition for Review under Rule 43 of the Rules of Court before the Court of Appeals (CA), contesting the DARAB decision and Resolution.
- The CA, in its April 24, 2015 Decision and subsequent October 1, 2015 Resolution, affirmed the DARAB ruling and dismissed the petition for review, noting that the petitioner availed of the wrong remedy by not filing with the Special Agrarian Court (SAC) as mandated by law.
- The petitioner raised two main issues:
- Whether the petition filed before the CA sought redress for an erroneous placement of the subject properties under the CARP rather than for determining just compensation.
- Whether the “just compensation” should be computed based on the classification of the properties as prawn farms and fishponds (commercial use) rather than as agricultural land.
- Petitioner further argued that the actual use of the properties (previous agricultural or aquaculture purpose) and improvements introduced by previous owners were not given due consideration by the LBP in its computation.
- Evidence Regarding Land Use and Classification
- The administrative records showed that the subject properties, at the time of the ocular inspections and valuation:
- Were classified as idle lands by the DAR.
- Had only incidental rice cultivation noted in 1999 despite earlier aquaculture activities or prawn farming evidenced by documents dating back to the early 1990s.
- Petitioner also submitted evidence such as a Memorandum of Agreement (MOA) and balance sheets from the previous owner (Filipinas Aquaculture Corporation) to claim that the properties were used for aquaculture.
- However, the administrative findings established that the properties had long ceased to be used for prawn or fish farming and continued as idle lands, thereby remaining subject to CARP coverage.
Issues:
- On the Procedural Proper Remedy
- Whether the petitioner, by directly appealing to the Court of Appeals under Rule 43, availed the proper remedy when the proper mode would have been to file a petition for determination of just compensation with the Special Agrarian Court (SAC) pursuant to Sec. 6, Rule XIX of the DARAB Rules and Sec. 57 of R.A. No. 6657.
- On the Substantive Classification of the Subject Properties
- Whether the properties should be considered exempt from CARP coverage on the basis that they were previously used as prawn farms and fishponds and had been reclassified as industrial lands through local resolutions.
- Whether the just compensation should be determined on the basis of their classification as commercial (prawn and fishpond farms) rather than as agricultural land.
- On the Valuation Method and Consideration of Improvements
- Whether the LBP and DARAB erred in computing the just compensation by failing to include the value of improvements (such as roads, waterways, and irrigation facilities) introduced by the previous owners.
- Whether the alternative valuations presented by independent appraisers should have been given due weight in determining the actual market value.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)