Case Summary (G.R. No. 215290)
Jurisdictional Background
This case pertains to a parcel of agricultural land in F. Simeon, Ragay, Camarines Sur, classified as unirrigated riceland, with a specific focus on a 135.2583-hectare portion of it. The land was under the coverage of PD 27, which facilitated the redistribution of land from landlords to tenant farmers. The claim for just compensation has gone through several administrative and judicial proceedings, leading to this petition for review.
Facts of the Case
The LBP initially valued the land at P1,301,498.09. After this valuation was rejected, the LBP made a deposit of this amount, which was later released to the petitioners in 2000. Following the Provincial Agrarian Reform Adjudicator's decision in 2001, the value was set at P4,641,080.465. The LBP subsequently filed a petition for the determination of just compensation, which was initially dismissed then reinstated. Prior to the trial court's consideration, the Feliciano heirs assigned their rights to Espiritu.
RTC Proceedings
In its Order, the Regional Trial Court (RTC) required the LBP to revalue the land, resulting in a new valuation of P7,725,904.05. While Espiritu accepted this valuation, she sought a 12% annual interest due to delays in payment. The RTC ruled that while the just compensation was correctly fixed at P7,725,904.05, it imposed a 12% annual interest from January 1, 2010, until full payment. The RTC later modified the terms regarding interest payment and subsequently dismissed both parties' motions for reconsideration.
CA Ruling
The Court of Appeals (CA) affirmed the RTC's valuation of P7,725,904.05 but adjusted the interest computation, ruling that interest of 12% should accrue from July 1, 2009, up until the LBP’s payment to Espiritu, culminating in a distinct amount owed to her due to the delayed execution of payment. The appeal to the CA regarding their computed total was denied again, ultimately leading to this petition before the Supreme Court.
Legal Issues at Hand
The fundamental question involves the correctness of the CA's determination of just compensation. The Supreme Court specified the legal framework guiding the valuation of expropriated lands, indicating that compensation must align with Republic Act No. 6657 (the Comprehensive Agrarian Reform Law), which takes precedence from the time of taking—specifically, the issuance of emancipation patents in 1989.
Court’s Ruling
The Supreme Court noted that the claim folder's receipt date by the LBP (December 2, 1997) was prior to the cut-off of July 1, 2009, thus necessitating that the just compensation be determined based on Section 17 of RA 6657, rather than the post-2009 amendments. The RTC and CA's failure to adhere to the pertinent DAR regulations meant that just compensation must be recalibrated.
Remand for Just Compensation Determination
The Supreme Court reversed the CA
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Case Overview
- This case involves a petition for review on certiorari regarding the Amended Decision of the Court of Appeals (CA) dated October 24, 2014.
- The petitioners are the heirs of Pablo Feliciano, Jr., represented by Victoria Aida Reyes Espiritu, seeking just compensation for a parcel of agricultural land.
- The respondent is the Land Bank of the Philippines (LBP).
Facts of the Case
- The Feliciano heirs are co-owners of a 300-hectare agricultural land in F. Simeon, Ragay, Camarines Sur, covered by Transfer Certificate of Title No. RT 3080 (4120).
- In 1972, a 135.2583-hectare portion of this land was classified as unirrigated riceland and placed under the coverage of Presidential Decree No. 27.
- In 1973, Certificates of Land Transfer were issued to 84 tenant-beneficiaries, who received Emancipation Patents in 1989.
- The LBP received the claim folder for the subject land from the Department of Agrarian Reform (DAR) on December 2, 1997.
- The DAR initially valued the land at P1,301,498.09, which the Feliciano heirs rejected, leading to a deposit by LBP in their name on January 26, 1998, and subsequent release of funds on March 24, 2000.
- After administrative proceedings, the Provincial Agrarian Reform Adjudicator fixed the just compensation at P4,641,080.465 on September 28, 2001.
- The LBP filed a petition for determination of just compensation in the Regional Trial Court (RTC) of Naga City, which was dismissed but later reinstated.
- The Feliciano heirs assigned their rights to Espiritu.
RTC Proceedings
- On May 4, 2011, the RTC or