Case Summary (G.R. No. 192345)
Factual Antecedents
The respondents were the registered owners of two agricultural parcels in San Antonio, Pilar, Sorsogon. The first parcel, with an area of 14.9493 hectares, was acquired under Presidential Decree No. 27 (PD 27), while the second parcel of 7.7118 hectares was acquired under Republic Act No. 6657 (RA 6657). LBP initially valued the first parcel at P177,657.98 and the second at P263,928.57, but the respondents rejected these valuations. Consequently, summary administrative proceedings were conducted before the Provincial Agrarian Reform Adjudication Board (PARAD).
Ruling of the Provincial Agrarian Reform Adjudicator
On April 11, 2003, the PARAD issued two separate decisions that recomputed the valuations proposed by LBP, determining the RA 6657-acquired property’s value at P1,542,360.00 based on nearby comparable sales and other factors. The PD 27-acquired land was valued at P983,663.94 using a specific formula that considered average gross production and actual support prices.
Ruling of the Regional Trial Court (RTC)
LBP, dissatisfied with PARAD's decisions, filed a Petition for Determination of Just Compensation with the RTC of Sorsogon City. On September 21, 2005, the RTC set the just compensation for the RA 6657-acquired property at P2,313,478.00 and for the PD 27-acquired land at P1,155,173.00. The RTC ruling took into account the valuation factors and the economic potentials of the properties, leading to the awards based on their agricultural production capabilities.
Ruling of the Court of Appeals (CA)
Upon appeal, the CA modified the RTC’s decision. It affirmed the formula used by PARAD for the PD 27-acquired property but corrected the actual support price to P35, in accordance with the relevant executive orders. For the RA 6657-acquired property, the CA proposed a different formula that included factors such as capitalized net income and the market value per tax declaration. This adjustment was necessary, as the court observed that LBP failed to account for the rising land values due to economic developments in the area.
Issues Presented
LBP raised several arguments against the CA’s decision, asserting that it disregarded valuation factors set forth under RA 6657 and mandated the remand of the case for re-evaluation of the PD 27-acquired land. The LBP further contended that the appellate court's imposition of interest was unwarranted.
LBP’s Argument
LBP argued that the CA improperly relied on external factors, asserting the primacy of the statutory framework in valuing the land. It sought the application of revised regulations and the latest valuation methodologies that were compelled by subsequent enactments affecting the agrarian reform laws.
Our Ruling
The Court partially granted LBP's petition, underscoring that the just compensation determination must adhere strictly to the provisions of Section 17 of RA 6657, especially considering amendments in RA 9700. Given the conflicting evaluations between lower courts, members of the Court found it pertinent to remand the case to the RTC for a thorough evaluation of just compensation, supported by adequate evidence.
Guidelines on Re
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Case Background
- The case involves a petition filed by the Land Bank of the Philippines (LBP) against spouses Esteban and Cresencia Chu concerning the amount of just compensation for two parcels of agricultural land acquired by the government under the agrarian reform program.
- The Court of Appeals' Decision dated January 18, 2010, and its Resolution dated May 24, 2010, are being challenged by LBP.
Factual Antecedents
- Respondents, Esteban and Cresencia Chu, were the registered owners of two parcels of land in San Antonio, Pilar, Sorsogon.
- The first parcel (14.9493 hectares) was acquired under Presidential Decree No. 27 (PD 27), initially valued at P177,657.98.
- The second parcel (7.7118 hectares) was acquired under Republic Act No. 6657 (RA 6657), valued at P263,928.57.
- Respondents rejected LBP's valuation, prompting summary administrative proceedings before the Provincial Agrarian Reform Adjudication Board (PARAD).
Ruling of the Provincial Agrarian Reform Adjudicator
- On April 11, 2003, the PARAD issued two decisions:
- The RA 6657-acquired property was valued at P1,542,360.00 based on comparable sales and a municipal resolution declaring the area as an industrial zone.
- The PD 27-acquired land was valued at P983,663.94 using a specific formula for land valuation.
Ruling of the Regional Trial Court
- Dissatisfied with PARAD’s decisions, LBP filed a Petition for Determination of Just Compensation before the RTC of Sorsogon City.
- On September 21, 2005, the RTC set the just compensation at P2,313,478.00 for the RA 6657-acquired pr