Title
Land Bank of the Philippines vs. Department of Agrarian Reform Adjudication Board
Case
G.R. No. 183279
Decision Date
Jan 25, 2010
Heirs of Adaza contested DAR's land valuation under CARP; SC upheld DARAB's order to release revalued compensation, emphasizing timely payment as essential to just compensation.
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Case Summary (G.R. No. 183279)

Case Background and Procedural History

  • The case involves a dispute between the Land Bank of the Philippines (LBP) and the Department of Agrarian Reform Adjudication Board (DARAB) regarding the valuation of land owned by the heirs of Vicente, Romeo, and Cesar Adaza.
  • The Adaza heirs owned a 359-hectare tract of land in Zamboanga del Norte, of which 278.4092 hectares were identified for compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP).
  • The LBP initially valued the land at PhP 786,654.46, which the Adazas rejected as unreasonably low.
  • The DAR ordered the LBP to deposit this amount, allowing the Adazas to access it while retaining the right to contest the valuation.
  • A summary administrative hearing was conducted, leading to a new valuation of PhP 3,426,153.80, which the Adazas also found insufficient, prompting them to appeal to the DARAB.

DARAB's Orders and Appeals

  • The Adazas filed a Motion to Withdraw Amended Valuation, seeking the difference between the initial and amended valuations, citing their dispossession since 1992.
  • The LBP contested this motion, arguing that the amended valuation had not been approved by the DAR, thus no execution could occur.
  • On January 2, 2006, the DARAB granted the motion, allowing the withdrawal of the amended valuation amount, emphasizing the urgency of the Adazas' situation.
  • The LBP's motion for reconsideration was denied, leading to the LBP's petition for certiorari to the Court of Appeals.

Ruling of the Court of Appeals

  • The Court of Appeals affirmed the DARAB's orders, finding no grave abuse of discretion in allowing the withdrawal of the amended valuation.
  • The appellate court emphasized the long delay the Adazas faced in receiving just compensation for their land, which had already been distributed to beneficiaries.
  • The legal issue presented was whether the DARAB could order the release of the incremental difference of the land valuation pending appeal.

Legal Arguments and Court's Ruling

  • The LBP argued that the DARAB lacked the authority to release the incremental difference without DAR approval of the amended valuation.
  • The Court ruled that the LBP's re-evaluation was valid and that the Adazas were entitled to withdraw the amount pending final determination of just compensation.
  • The Court highlighted the principle of just compensation, which requires timely payment to landowners deprived of their property.

Just Compensation and Landowners' Rights

  • The Court reiterated that landowners are entitled to withdraw amounts deposited for their land under CARP, regardless of whether the valuation is provisional or final.
  • The provisions of the CARP Law support the landowners' right to compensation, emphasizing the need for prompt payment to ...continue reading

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