Case Summary (G.R. No. 210422)
Relevant Dates and Legal Framework
The decision of the case was rendered on September 7, 2022, invoking the principles under the 1987 Philippine Constitution, considering the provisions of Republic Act No. 6657 (R.A. No. 6657), which governs agrarian reform and the determination of just compensation.
Background Facts of the Case
Spouses Cortez owned approximately 16.5415 hectares of coconut land located at Villahermosa, Daraga, Albay, covered by Transfer Certificate of Title No. T-45714. They offered the property for acquisition on January 5, 2000, prompting the Department of Agrarian Reform (DAR) to issue a notice of coverage in April 2000. Following a field investigation in April 2000, it was determined that only 6.0004 hectares of their land was fit for acquisition.
Initial Compensation Assessment by LBP
On January 15, 2002, the Register of Deeds partially canceled the title and issued a new title under the name of the Republic of the Philippines for the 6.0004 hectares. LBP conducted a preliminary valuation of the land, utilizing the two-factor formula prescribed by DAR Administrative Order No. 5, Series of 1998, which resulted in a preliminary valuation of P106,542.98. However, this amount was rejected by the spouses Cortez, leading to a provisional deposit of the amount in December 2001.
DARAB and RTC Determinations
The dispute escalated to the DAR Adjudication Board (DARAB), which assessed the compensation at P183,273.93. LBP contested this, leading to a jurisdictional petition before the Regional Trial Court (RTC) of Legazpi City. In its ruling on December 21, 2011, the RTC established just compensation at P397,958.41, relying on a recalculated value based on the findings from a court-appointed commissioner, also referencing the relevant laws and administrative issuances.
Affirmation by the Court of Appeals
On July 9, 2013, the Court of Appeals affirmed the RTC ruling but did not explicitly address the issue regarding the modification of the reckoning dates used to determine production values and prices. This omission became a critical point in LBP's arguments against the RTC's decision.
LBP's Arguments and Contentions
LBP argued that the RTC improperly utilized the formula and presumptive date of taking prescribed under DAR Administrative Order No. 1, Series of 2010, which LBP claimed was inappropriate for acquisitions made under R.A. No. 6657. It contended that the RTC overstepped its jurisdiction by altering the established reckoning dates for determining relevant production data.
Court's Ruling on Discretion and Just Compensation
The ruling emphasized that while the RTC has the authority to determine just compensation, this must be done in accordance with established factors under R.A. No. 6657. Just compensation is defined as the fair equivalent of the property taken. The court reiterated that the final determination of just compensation is a judicial function that requires the courts to consider particular criteria laid out by the law and applicable administrative guidelines.
Compliance with DAR Issuances
The court established that the guidelines and formulas set forth by DAR are binding, and courts should adhere to them unless substantial justification for deviation is provided. In this case, the R
...continue readingCase Syllabus (G.R. No. 210422)
Overview of the Case
- This case involves a Petition for Review on Certiorari filed by the Land Bank of the Philippines (LBP) on January 17, 2014, contesting the Decision dated July 9, 2013, and the Resolution dated December 16, 2013, from the Court of Appeals (CA).
- The CA's decision upheld the Regional Trial Court (RTC) of Legazpi City, which had determined the just compensation for an expropriated 6.0004 hectare land owned by spouses Lydia and Carlos Cortez at P397,958.41.
- The RTC's computation for just compensation was based on the formula outlined in the Department of Agrarian Reform (DAR) Administrative Order No. 5, Series of 1998, but differed in the reckoning date used for production data.
Background Facts
- Spouses Cortez owned a coconut land identified as Lot 181893, Cad. 56, located in Villahermosa, Daraga, Albay, with an area of approximately 16.5415 hectares, covered by Transfer Certificate of Title No. T-45714.
- On January 5, 2000, they offered the property for acquisition under the Comprehensive Agrarian Reform Program (CARP).
- Notice of coverage was issued by the DAR in April 2000, and a field investigation revealed that only 6.004 hectares were suitable for acquisition.
- The DAR subsequently requested LBP to value the land in September 2001, and by January 15, 2002, the title for the 6.0004 hectares was issued in the name of the Republic of the Philippines.
Valuation Process and Dispute
- LBP initially valued the subject pr