G.R. No. 217492 - Philippine Veterans Bank vs. Bases Conversion and Development Authority

A 2,511 sq. m. lot covered by CLOA No. 00604434 and TCT No. 15767 in the name of Marcelo Sagun.
A 1,504 sq. m. lot covered by CLOA No. 00604433 and TCT No. 15762 in the name of Edner Sagun.

Initially, the properties were owned by Belmonte Agro-Industrial Development Corporation (BAIDECO), which later mortgaged them to Philippine Veterans Bank (PVB).
PVB foreclosed and acquired the properties at a public auction in 1982 but was later placed under liquidation and subsequently rehabilitated.

The Comprehensive Agrarian Reform Law (CARL), RA 6657, was enacted, placing the Subject Properties under its coverage.
The lands were distributed to the farmer-beneficiaries, the Saguns, through proper processes:

The Landbank of the Philippines (LBP) deposited advance payments based on its own valuation.
The Department of Agrarian Reform (DAR) issued CLOAs on September 25, 2001, followed by the issuance of TCTs on November 21, 2001.

PVB was not informed by LBP of the expropriation prior to the issuance of the CLOAs and TCTs, causing later complications when PVB attempted to assert its ownership.

Upon discovering that the Subject Properties had been distributed to the Saguns, PVB filed an action for the declaration of nullity of the Emancipation Patents (EPs) and TCTs, contending non-notification by DAR.
PVB later withdrew its nullity case after the Court ruled that controversies on CARP implementation fall within DAR’s jurisdiction.
PVB initiated a separate petition for the determination of just compensation before the Office of the Regional Agrarian Reform Adjudicator, contending that it should receive compensation for its alleged loss.

Expropriation by the Bases Conversion and Development Authority (BCDA) for the SCTEX Project

In December 2003, BCDA instituted expropriation proceedings for the SCTEX project to acquire the Subject Properties from Marcelo and Edner Sagun.
The Regional Trial Court (RTC) rendered a decision in August 2011, affirming BCDA’s right to the affected property and setting the just compensation for the affected lot in Edner Sagun’s name.
Subsequent modifications in the RTC ruling in November 2011, after which LBP was dropped as a defendant since the Saguns had settled their obligation to the bank.
The RTC noted that although the issuance of TCTs to the Saguns was procedurally improper under the CARL, PVB’s contention that it should receive the just compensation was untenable because the debate had shifted to the proper beneficiary for the compensation.

PVB appealed the RTC decision, asserting that as the owner of the Subject Properties it is entitled to the just compensation awarded in the expropriation proceeding.
In its June 16, 2014 Decision, the Court of Appeals (CA) affirmed the RTC ruling, indicating that:

Since the distribution of the Subject Properties under CARP was completed, the rightful owners are the Saguns, not PVB.
Awarding compensation to PVB would result in double recovery or unjust enrichment.

Whether PVB, as the purported owner of the Subject Properties before their distribution under CARP, is entitled to receive the just compensation awarded in the SCTEX expropriation proceeding.
Whether a landowner can claim compensation from more than one expropriation proceeding when the properties have already been distributed to bona fide beneficiaries.

Whether the issuance of the CLOAs and TCTs in favor of the Saguns makes them the lawful owners of the Subject Properties despite the prior mortgage foreclosure by PVB.
Whether awarding just compensation to PVB in the SCTEX proceedings would amount to unjust enrichment, given that its claim is already subsumed under the compensation provided for under the CARP.

Whether the effective "taking" of the property occurred at the moment of the CARP expropriation (with the issuance of the CLOAs and TCTs) rather than when the SCTEX expropriation was initiated by BCDA.