G.R. No. 93661 - Sharp International Marketing vs. Court of Appeals

The case involves the aborted sale of the Garchitorena estate in Camarines Norte in connection with the Comprehensive Agrarian Reform Program (CARP).
The property, consisting of eight parcels measuring a total of 1,887.819 hectares, became the subject of conflicting transactions involving both private and government actors.

Initial Private Transaction with United Coconut Planters Bank (UCPB) and Sharp International Marketing

On April 27, 1988, UCPB entered into a Contract to Sell with Sharp International Marketing for a purchase price of P3,183,333.33, with conversion to a Deed of Absolute Sale upon full payment.
Sharp later registered the property on December 6, 1988, following the execution of the Deed of Absolute Sale on December 1, 1988.

On May 14, 1988, before acquiring the land outright, petitioner Sharp offered to sell the property to the Government for an initial price of P56,000,000.00 (later increased to P65,000,000.00).
Various government agencies processed the offer from June to November 1988, leading to a recommendation by the Bureau of Land Acquisition and Distribution under the Department of Agrarian Reform (DAR) for acquisition at P35,532.70 per hectare, approximately P67,000,000.00.

On December 27, 1988, DAR and LBP created a Compensation Clearing Committee (CCC) to expedite the acquisition process, followed by the issuance of orders by DAR Secretary Philip Ella Juico regarding the purchase price.
A critical Deed of Absolute Sale was signed on January 9, 1989, by Secretary Juico and petitioner Alex Lina, with subsequent involvement by LBP—with reservations noted by its Executive Vice President on January 17, 1989.

The contested sale price of P62,725,077.29 was determined by CCC, a figure that far exceeded the original acquisition cost of approximately P3 million, raising concerns regarding the drastic increase in land valuation.
LBP President Deogracias Vistan, questioning the compensation and influenced by the finding that Sharp had obtained the property for a nominal amount earlier, refused to approve the transaction by not signing the Deed of Absolute Sale.

Sharp repeatedly demanded that the LBP sign the contract in order to perfect the agreement.
Sharp filed a petition for mandamus with the Supreme Court, seeking to compel the LBP President to execute the Deed of Absolute Sale despite the inherent discretionary powers and reservations regarding the high price.
The Court of Appeals dismissed the petition on October 31, 1989, and the Supreme Court was then faced with reviewing whether mandamus was applicable, particularly given the nature of LBP’s discretionary review under Section 18 of RA 6657.

Whether Sharp International Marketing possesses a clear and well-defined legal right to compel the Land Bank of the Philippines (LBP) to sign the Deed of Absolute Sale despite the objections raised regarding the high compensation amount.

Does the petitioner's contractual position confer an enforceable right that mandates the LBP’s compliance?
Can the court issue a writ of mandamus to compel an act that involves the exercise of judgment and discretion by the LBP President?

The applicability and limits of mandamus when the duty in question is discretionary rather than ministerial.

Is the act of signing the Deed of Absolute Sale by the LBP President purely ministerial, or does it involve a significant discretionary policymaking function?
Does the decision of DAR Secretary Juico and the related order limit the LBP’s prerogative to review and evaluate the compensation amount?

Whether the valuation of the property at P62,725,077.29, as required by the DAR’s process, constitutes “just compensation” under RA 6657 and related guidelines.

How does the drastic increase from the acquisition price of P3 million to P62 million affect the legitimacy of the transaction?
What implications does the public outcry and investigative findings have on the enforceability of the sale?