Case Summary (G.R. No. 213161)
Background
The case involves two parcels of land, Lot Nos. 6003 and 6004, with a total area of 16.1089 hectares, owned by respondents Rene I. Latog and Nelda Lucero. The properties are covered under a Transfer Certificate of Title (TCT) No. T-86890 and were offered for sale to the Department of Agrarian Reform (DAR) for acquisition at a price of P150,000.00 per hectare. Following the evaluation of these parcels, LBP recommended a significantly lower compensation amount of approximately P137,570.68 and P167,674.63 for the two parcels.
Proceedings and Rulings
After LBP's valuation was rejected by the respondents, they appealed to the Provincial Agrarian Reform Adjudication Board (PARAB), which upheld LBP's findings. Subsequently, the respondents filed a Complaint for judicial determination of just compensation with the Regional Trial Court (RTC). The trial court rendered a decision adjusting the just compensation to P605,291.91 alongside an order for 12% interest per annum from December 1, 2001, until full payment.
LBP's motion for reconsideration was denied, prompting it to file a Petition for Review with the Court of Appeals (CA). The CA modified the RTC's decision by deleting the interest component and slightly increasing the compensation amount to P611,445.41, arguing that the formula mandated by DAR Administrative Order No. 5, series of 1998, was not mandatory.
Legal Standards for Just Compensation
In the case of Land Bank of the Philippines v. American Rubber Corporation, the Supreme Court defined just compensation to encompass the "full and fair equivalent" of the property taken, emphasizing that the measure of compensation should reflect the owner's loss rather than the taker’s gain. Section 17 of R.A. No. 6657 stipulates the factors to be considered in determining just compensation, including acquisition cost, current values of similar properties, sworn valuations by the owner, and other relevant assessments.
Court's Analysis
The Court noted that while the formula employed by LBP was appropriate in terms of lacking certain factors, the absence of a clear justification for not applying the main valuation formula from DAR A.O. No. 5 undermined its validity. The Court emphasized the necessity for
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Case Information
- Petitioner: Land Bank of the Philippines (LBP)
- Respondents: Spouses Rene I. Latog and Nelda Lucero
- G.R. No.: 213161
- Date of Decision: February 01, 2023
- Nature of Petition: Petition for Review on Certiorari under Rule 45 of the Rules of Court
- Court: Third Division of the Supreme Court of the Philippines
Background of the Case
- The case revolves around two parcels of land in Cabatangan, Lambunao, Iloilo, covering 16.1089 hectares, under Transfer Certificate of Title No. T-86890, owned by the respondents.
- Respondents offered these lands for sale to the Department of Agrarian Reform (DAR) under the Comprehensive Agrarian Reform Law (R.A. No. 6657), seeking P150,000.00 per hectare (totaling P2,400,000.00).
- The valuation set by LBP for just compensation was significantly lower: P137,570.68 for Lot No. 6003 and P167,674.63 for Lot No. 6004.
Procedural History
- Respondents rejected LBP's valuation and sought redress from the Provincial Agrarian Reform Adjudication Board (PARAB), which upheld LBP's valuation.
- Consequently, the respondents filed a judicial complaint in the Regional Trial Court (RTC) on May 10, 2002, which later led to an amended complaint.
- On September 28, 2007, the RTC adjusted the