Case Summary (G.R. No. 146735)
Applicable Law
This case hinges on the evaluation of just compensation under the framework of Republic Act No. 9700, which amends Republic Act No. 6657, and the administrative orders that govern land valuation for agrarian reform. Notably, DAR Administrative Order No. 1, Series of 2010, provides the formula for determining the just compensation for lands acquired under agrarian reform programs.
Background of the Case
On February 3, 1999, the respondents petitioned the Regional Trial Court (RTC) for the determination of just compensation, asserting they have not received the payment for their land, which they claim should be valued at no less than P300,000.00 per hectare. The Land Bank contended that the petition lacked merit as it had not received the required Claim Folder from the DAR.
RTC and CA Decisions
The RTC, on September 6, 2013, fixed the just compensation for the land at P1,523,204.50 based on the value presented by the Land Bank, calculated using the formula prescribed by DAR AO No. 1. The RTC also mandated the imposition of legal interest at 12% per annum starting from 1998 until June 30, 2013, and 6% per annum thereafter. The Land Bank's motion for reconsideration was denied, leading to an appeal to the Court of Appeals (CA).
The CA upheld the RTC’s ruling on April 25, 2017, reiterating the imposition of interest. The Land Bank sought a reconsideration of this decision, which was subsequently denied by the CA.
Legal Issues Before the Court
The central issue was whether the CA erred in holding the Land Bank liable for legal interest on the just compensation amount. The focus was on the appropriate reckoning date for the legal interest and whether sufficient justification existed for such an imposition, given the circumstances surrounding the compensation determination.
Supreme Court’s Ruling
The Supreme Court affirmed the CA's decision with modifications regarding the interest calculations. The court reiterated the principle of just compensation, which encompasses not just the correct monetary value but also a timely payment. It emphasized the validity of imposing interest on unpaid just compensation from a reasonable period rather than the time of taking, which in this case was determined to be from June 30, 2009 to ensure fairness given the variance in land values and inflation.
The Court ultimately established that interest on the unpaid balance of the ju
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Case Citation
- Jurisprudence: 853 Phil. 649; 116 OG No. 38, 5961 (September 21, 2020)
- G.R. No. 233401, June 17, 2019
Parties Involved
- Petitioner: Land Bank of the Philippines (LBP)
- Respondents: Heirs of the Estate of Mariano and Angela Vda. De Veneracion, represented by Crisostomo Q. Veneracion
Background of the Case
- The respondents are co-owners of a 24.4170 hectare parcel of riceland in Barrio Taguilid, Pamplona, Camarines Sur, covered by Transfer Certificate of Title No. RT 1405 (4487).
- In 1972, a portion of this land, specifically 21.8513 hectares, was acquired by the Department of Agrarian Reform (DAR) under Presidential Decree No. 27 and distributed to farmer-beneficiaries.
- On February 3, 1999, the respondents filed a petition before the Regional Trial Court (RTC) for the fixation of just compensation, collection of rental arrears, and damages, alleging non-receipt of just compensation for the subject land valued at not less than P300,000.00 per hectare.
Procedural History
RTC Ruling (September 6, 2013):
- The RTC fixed just compensation at P1,523,204.50, based on LBP's valuation of P69,707.73 per hectare.
- Imposed a legal interest rate of 12% per annum from 1998 until June 30, 2013, and thereafter 6% until full payment.
Court of Appeals (CA) Ruling (April 25, 2017):
- Affirmed RTC'