Case Summary (G.R. No. 164195)

Background of the Case

• This case involves a dispute between Apo Fruits Corporation and Hijo Plantation, Inc. (petitioners) against the Land Bank of the Philippines (respondent) regarding just compensation for expropriated agricultural land.
• The Supreme Court resolved the Land Bank's second motion for reconsideration dated December 14, 2010, and addressed prior resolutions from October 12, 2010, and November 23, 2010.

Motion for Reconsideration by Land Bank

• The Land Bank filed a second motion for reconsideration claiming:
  • The “transcendental importance” standard does not apply.
  • The Court should not negate the immutability of final judgments nor abrogate vested rights.
  • Just compensation must consider the context of social justice.
  • In any case, only a 6% per annum interest should apply.
• The Court rejected the motion, emphasizing that it was a prohibited motion that could no longer be entertained.

Court's Ruling on the Second Motion for Reconsideration

• The Court found no merit in the Land Bank's arguments and maintained that the previous rulings were final.
  • Vote Outcome: 9 to 2 against entertaining the motion, reiterating the finality of the October 12, 2010 decision.

Legal Principles Addressed

Doctrine of Immutability of Judgments

• The Court reaffirmed the principle that judgments become immutable once final, with very few exceptions.
• Exceptions must be justified by the "higher interest of justice," requiring a two-thirds majority for reconsideration.

Just Compensation

• The right to just compensation for expropriated property is constitutionally guaranteed under Section 9, Article III of the 1987 Constitution.
• Just compensation must be full, fair, and paid without delay.
• The government’s failure to pay just compensation in a timely manner constitutes a violation of the property owner's rights.

Arguments on Delay and Interest

• The Land Bank argued that delays in payment should not be attributed to it; however, the Court found that:
  • There was a 12-year delay in the payment of just compensation.
  • The Land Bank's initial valuation was grossly inadequate compared to the RTC’s final valuation.

Procedural Issues Raised

• Justice Abad raised concerns about the Internal Rules of the Supreme Court regarding motions for reconsideration.
• The Court emphasized that the voting procedure complied with constitutional requirements, even absent an explicit prior ruling on accepting the motion.

Denial of Oral Arguments and OSG Intervention

• The Court denied the Land Bank's request for oral arguments, stating that the written submissions provided sufficient information.
• The Office of the Solicitor General's (OSG) motion to intervene was also denied, as it did not present new arguments.

Key Takeaways

• The Supreme Court firmly upheld the principle of just compensation, emphasizing that delays in payment ar

...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 set the interest due at 12% per annum, which was later deleted by the

...continue reading