Case Summary (G.R. No. 164195)
Antecedents
On October 12, 1995, AFC and HPI voluntarily offered the lands in question for sale, leading to an initial valuation by Land Bank at P165,484.47 per hectare for AFC and P164,478,178.14 for HPI. These valuations were rejected, prompting Land Bank to open deposit accounts for the petitioners with partial amounts credited. Subsequently, separate complaints were filed by AFC and HPI for the determination of just compensation when no action was taken by the DAR Adjudication Board after three years. The Regional Trial Court (RTC) in Tagum City eventually ruled on the matter.
RTC Decision
On September 25, 2001, the RTC rendered its decision in favor of the petitioners, setting the total just compensation for the lands at P1,383,179,000. It included orders for interest on the amount from the date of taking until full payment and fees for court-appointed commissioners and attorney’s fees.
Modifications and Land Bank's Appeal
Land Bank filed for reconsideration, which resulted in modifications to the RTC's decision on December 5, 2001. Land Bank then attempted to appeal the RTC’s decision, but the RTC denied due course due to procedural issues as established in previous jurisprudence. This led to Land Bank filing a petition for certiorari in the Court of Appeals, which granted the appeal and nullified the RTC's order.
CA and Supreme Court Ruling
AFC and HPI contested the CA’s decision and filed an appeal with the Supreme Court, raising issues such as whether the CA's ruling was in accordance with the law and if Land Bank was bound by previous decisions. In February 2007, the Supreme Court, while affirming the CA's ruling on procedural grounds, also ruled in favor of the petitioners on the merits of the compensation amount.
Second Motion for Reconsideration
Following the decisions, Land Bank sought reconsideration and argued against the awards of interest and attorney's fees. The Third Division of the Supreme Court partially granted Land Bank's motion on December 19, 2007, deleting the award of interest and attorney's fees, reasoning that there was no undue delay in the compensation.
Ruling on Immutability of Judgment
In the ensuing resolution, the Supreme Court denied AFC and HPI's second motion for reconsideration, emphasizing the doctrine of immutability of judgments, which mandates finality in judicial decisions to avoid delays in the administration of justice.
Legal Interest on Just Compensation
The Court reiterated that legal interest is typically due only when there is a delay in payment of just compensation. In this case, the Court found that Land Bank had acted without delay, thus negating any entitlement to 12% annual intere
...continue readingCase Syllabus (G.R. No. 164195)
Case Background
- The case originated from the decision of the Third Division dated February 6, 2007, which favored petitioners Apo Fruits Corporation (AFC) and Hijo Plantation, Inc. (HPI).
- On December 19, 2007, the Third Division modified its decision to remove the award of interest and attorney's fees following a motion for reconsideration by the respondent, Land Bank of the Philippines (Land Bank).
- The petitioners subsequently filed a second motion for reconsideration regarding the denial of legal interest and attorney's fees.
Antecedents
- On October 12, 1995, AFC and HPI voluntarily offered to sell lands under Republic Act No. 6657 (Comprehensive Agrarian Reform Law).
- The Department of Agrarian Reform (DAR) referred their applications to Land Bank for initial valuation, which was set at P165,484.47 per hectare for AFC and P164,478,178.14 for HPI.
- The valuations were rejected, prompting Land Bank, advised by DAR, to open deposit accounts for the petitioners, crediting amounts of P26,409,549.86 and P45,481,706.76 respectively.
- Both petitioners withdrew these amounts but later filed separate complaints with the DAR Adjudication Board (DARAB) on February 14, 1997.
- After DARAB failed to act on their complaints after more than three years, the petitioners escalated the matter to the Regional Trial Court (RTC) acting as a Special Agrarian Court (SAC) in Tagum City, which led to the filing of Agrarian Cases No. 54-2000 and No. 55-2000.
RTC Decision and Modifications
- The RTC rendered its decision on September 25, 20