Case Summary (G.R. No. 164195)

Resolution of Land Bank's Second Motion for Reconsideration

The Supreme Court addressed the Land Bank of the Philippines' (LBP) second motion for reconsideration regarding previous resolutions. The motion also requested oral arguments. The Court emphasized that the second motion for reconsideration is prohibited and reiterated its previous rulings, indicating a final resolution to the case.

• LBP filed a second motion for reconsideration on December 14, 2010.
• The Court had previously issued resolutions on October 12, 2010, and November 23, 2010.
• The Court denied the request for oral arguments, stating that the existing records were sufficient for decision-making.

Arguments Presented by Land Bank

LBP's motion presented several arguments, including the inapplicability of the "transcendental importance" test, the immutability of final judgments, and the context of social justice in determining just compensation. The Court noted that it had already addressed the interest payment issue in its earlier resolution.

• LBP argued that the "transcendental importance" test does not apply to this case.
• The motion contended that the Court's ruling negated the doctrine of immutability of final judgments.
• LBP emphasized the need to consider social justice in determining just compensation for expropriated agricultural property.

Examination of Justice Abad's Observations

Justice Roberto A. Abad raised concerns regarding the procedural handling of the second motion for reconsideration, suggesting that the Court should have voted on the validity of the October 12, 2010 resolution before addressing the merits. The Court ultimately rejected this observation.

• Justice Abad questioned the application of Section 3, Rule 15 of the Internal Rules of the Supreme Court.
• He argued that the Court should have voted on whether to entertain the underlying motion before discussing its merits.
• The Court found no merit in Justice Abad's observations and proceeded to vote on the second motion for reconsideration.

Historical Context of the Case

The case's history was recounted, detailing its progression through the judicial system. The original decision affirmed the Regional Trial Court's (RTC) valuation of just compensation, which was later contested by LBP. The case was eventually referred to the En Banc for final resolution.

• The Third Division initially handled the case, affirming the RTC's decision on February 6, 2007.
• Subsequent motions for reconsideration led to the case being referred to the En Banc.
• The En Banc denied the petitioners' second motion for reconsideration on December 4, 2009.

Governing Rules on Second Motions for Reconsideration

The Court outlined the rules governing second motions for reconsideration, emphasizing that such motions are generally not entertained unless exceptional circumstances arise. The rules require a two-thirds vote of the Court's actual membership to grant exceptions.

• Section 2, Rule 52 of the Rules of Court prohibits second motions for reconsideration.
• Section 3, Rule 15 of the Internal Rules allows exceptions only in the higher interest of justice.
• The Constitution mandates that cases requiring en banc decisions must have a majority concurrence from participating members.

Court's Ruling on the Second Motion for Reconsideration

The Court found no merit in LBP's second motion for reconsideration and upheld its previous rulings. The vote indicated a clear rejection of LBP's arguments, reinforcing the finality of the Court's earlier decisions.

• The Court voted 9 to 2 against entertaining LBP's second motion for reconsideration.
• The ruling from November 23, 2010, was reiterated, emphasizing the finality of the case.
• The Court mandated that no further pleadings would be entertained.

Public Interest in Just Compensation

The Court addressed the argument that the case did not involve a matter of transcendental importance. It asserted that the right to just compensation in expropriation cases is a public interest issue, particularly in the context of agrarian reform.

• The right to just compensation is constitutionally guaranteed under Section 9, Article III of the 1987 Constitution.
• The Court emphasized that the case's outcome affects not only the petitioners but also the broader agrarian reform program.
• The Court rejected the notion that the case only involved private interests.

Delay in Payment and Interest on Just Compensation

The Court examined the delay in payment of just compensation and the implications of this delay on the landowners. It concluded that the LBP's actions contributed to the prolonged legal proceedings, justifying the award of interest.

• The Court noted that the LBP's initial valuation was significantly lower than the RTC's determination.
• The delay in payment was attributed to the government's undervaluation and inaction.
• The Court reaffirmed that just compensation must be paid without delay, and the award of 12% interest was justified.

LBP's Argument on Social Justice

LBP contended that the just compensation awarded should be viewed within the context of social justice, arguing that the interest payment undermined the agrarian reform program's objectives. The Court rejected this argument, asserting that just compensation is a constitutional requirement.

• The Court clarified that the agrarian reform program does not exempt the government from paying just compensation.
• The constitution...continue reading

Case Syllabus (G.R. No. 164195)

Case Reference

• Citation: 662 Phil. 572 EN BANC
• G.R. No.: 164195
• Date: April 05, 2011
• Petitioners: Apo Fruits Corporation and Hijo Plantation, Inc.
• Respondent: Land Bank of the Philippines

Procedural History

• The case revolves around the 2nd Motion for Reconsideration filed by the Land Bank of the Philippines (LBP) addressing previous Resolutions dated October 12, 2010, and November 23, 2010.
• The Office of the Solicitor General (OSG) sought to intervene and submit a Motion for Reconsideration-in-Intervention dated February 15, 2011.

Arguments Presented by LBP

• Transcendental Importance: LBP contends that the doctrine of "transcendental importance" does not apply to this case.
• Immutability of Judgments: LBP argues that this doctrine should not be violated in favor of the government’s vested rights.
• Context of Just Compensation: LBP asserts that just compensation for expropriated agricultural property should align with social justice.
• Interest Rate: LBP claims that if interest payments are applicable, it should only be at a rate of six percent (6%) per annum.

Court’s Ruling on the Motion for Reconsideration

• The Court finds no merit in LBP's motion and emphasizes the prohibition against entertaining a second motion for reconsideration.
• The Court examines LBP’s arguments but concludes they do not merit reopening the case.
• The Court reiterates its previous ruling with finality, denying any further motions or pleadings.

Historical Background of the Case

• The case originated with the Third Division of the Supreme Court, which initially affirmed the RTC's decision regarding just compensation.
• The RTC had s...continue reading