Case Digest (G.R. No. 186339) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Vivencio, Eugenio, Joji and Myrna Mateo v. Department of Agrarian Reform, Land Bank of the Philippines and Mariano T. Rodriguez, et al. (G.R. No. 186339, February 15, 2017), the petitioners—the Mateo siblings—owned 112.3112 hectares of coconut and rice lands in Barangay San Isidro, Fabrica, Bacon, City of Sorsogon, covered by TCT No. T-22822. In June 1994, under Republic Act No. 6657 (the Comprehensive Agrarian Reform Program), the DAR entered the property, and the Land Bank of the Philippines (LBP) valued it at ₱52,000/ha, an offer the Mateos rejected. On April 30, 1997, they filed before the Regional Trial Court of Sorsogon City, Branch 52, sitting as a Special Agrarian Court (SAC), Civil Case No. 97-6331, a complaint for determination of just compensation. The SAC conducted a full trial, appointed two commissioners, received extensive evidence on comparable sales, crop yields, zonal values and the Provincial Ordinance No. 03-99 schedule, and on July 4, 2002 rendered judgme Case Digest (G.R. No. 186339) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Petitioners: Vivencio, Eugenio, Joji and Myrna Mateo—registered owners of 1,323,112 sqm (112.3112 ha) of coconut and riceland in Fabrica, Bacon District, City of Sorsogon, covered by TCT No. T-22822.
- Respondents: Department of Agrarian Reform (DAR), Land Bank of the Philippines (LBP, financial intermediary under CARP), and farmer-beneficiaries under RA 6657 (CARP).
- Expropriation and Preliminary Valuation
- June 1994: DAR entered the subject property for CARP coverage; LBP offered ₱52,000/ha as just compensation. Petitioners rejected this valuation.
- DAR Adjudication Board (DARAB) conducted summary proceedings (dates not specified), adopting LBP’s valuation: ₱6,112,598.86 for 72.2268 ha and ₱2,949,313.14 for 36.3196 ha. Petitioners again rejected.
- Judicial Proceedings Before the SAC
- April 30, 1997: Petition for determination of just compensation filed as Civil Case No. 97-6331 before the RTC of Sorsogon City, Branch 52, sitting as Special Agrarian Court (SAC).
- Respondents’ Answers: LBP and DAR argued the complaint was premature for non-exhaustion of administrative remedies. Pre-trial ensued and closed.
- Evidence Adduced at Trial
- Petitioners:
- Testimonies of Dr. Eleseo Mateo (father), Engr. Florencio Dino (commissioner), Manuel Docot (farmer) and Danilo Federio (caretaker).
- TCT No. T-22822; Memorandum of Valuation (MoV); Claim Folder Profile and Valuation Summary; deeds of sale of nearby parcels (₱300,000–₱400,000/ha); newspaper clipping of land sale at ₱350,000/ha; Engr. Dino’s appraisal; deed of sale to NHA at ₱245,000/ha.
- DAR: Testimonies of Romeo Brotamante (agriculturist), Ireneo Defeo (gov’t employee), Cresenciano Lagajeno (farmer); Field Investigation Report (March 29, 1996); ledger cards (Dec 1994–Jun 1997); passbooks showing ₱601,789.97 withdrawns.
- LBP: Testimony of Monita Balde; Claims Valuation and Processing Form.
- SAC Decision (July 4, 2002)
- Appointment of Commissioners: Engr. Dino for petitioners and Jesus Empleo for LBP.
- Adopted Engr. Dino’s report (land FMV P4,764,323; trees/improvements P1,251,980; total P6,016,303) but deemed too low given location within city limits and comparables commanding ≥P350,000/ha.
- Adjusted land FMV to P500,000/ha; computed additional values for produce (1994–2002) and improvements; recapitulated:
- Coconut land (108 ha) FMV: ₱54,000,000
- Net copra produce: ₱13,057,397
- Improvements & trees: ₱1,251,930
- Riceland (3.7649 ha) FMV & produce: ₱3,436,085
- Less prior lease rentals: ₱601,789.00
- Grand total just compensation: ₱71,143,623.00
- Decretal: Ordered LBP to pay petitioners ₱71,143,623 less prior payments, without pronouncement as to costs.
- Court of Appeals Proceedings
- August 4, 2008 Decision: CA granted LBP and DAR appeals, holding SAC lacked jurisdiction due to non-exhaustion of DARAB’s primary jurisdiction; complaint dismissed without prejudice.
- January 28, 2009 Resolution: Motion for reconsideration by petitioners denied.
Issues:
- Jurisdiction and Exhaustion of Administrative Remedies
- Did the SAC have jurisdiction to determine just compensation absent prior summary administrative proceedings by DARAB?
- Was the petitioners’ complaint premature for failure to exhaust administrative remedies?
- Compliance with Section 17 of RA 6657 and DAR Administrative Orders
- Did the SAC disregard the factors prescribed by Section 17 of RA 6657 in computing just compensation?
- Did the CA err in holding that the SAC failed to apply Section 17 and relevant DAR valuation formulas?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)