Case Summary (G.R. No. 161834)
Applicable Law
The legal framework guiding this case is Republic Act No. 6657, also known as the Comprehensive Agrarian Reform Law, and its procedures particularly concerning compensation for lands acquired under the agrarian reform program. This law mandates that just compensation be granted to landowners from whom the State takes land for redistribution to agrarian reform beneficiaries.
Procedural History
The Respondent, the registered owner of a 37.1010-hectare agricultural land, offered her land for sale to the Department of Agrarian Reform (DAR) for a price of ₱2,000,000.00 per hectare. The Land Bank of the Philippines appraised the land at ₱1,145,806.06, which was rejected by the Respondent. Following this rejection, the Land Bank deposited this amount as provisional compensation. Subsequently, the DAR Adjudication Board (DARAB) determined just compensation to be ₱10,294,721.00, which was higher than the amount initially offered by the Land Bank. Disagreements led to multiple proceedings, including motions for reconsideration and petitions for judicial determination of just compensation before the Special Agrarian Court.
Issues Presented
The primary legal questions raised by the Petitioner include:
- Whether the order from the Special Agrarian Court mandating the deposit of the DARAB-determined compensation amount had any legal basis, given that the provisional compensation deposit of ₱1,145,806.06 was made in compliance with Section 16 of RA No. 6657.
- Whether the Special Agrarian Court has the jurisdiction to review and enforce the decision of the DARAB regarding compensation.
Court of Appeals Decision
The Court of Appeals affirmed the Special Agrarian Court’s directive, asserting that the deposit regarding provisional compensation required by the Special Agrarian Court should align with amounts determined by the DARAB and not merely the initial offer of the Land Bank. They reasoned that the law’s procedural sequence mandates a complete deposit of just compensation before the State can take possession of the land.
Supreme Court Ruling
The Supreme Court reversed the decision of the Court of Appeals, ruling in favor of the Petitioner. The Court maintained that under Section 16 (e) of RA No. 6657, the amounts to be deposited correspond with the provisional compensation as initially offered by the DAR/LBP, which is ₱1,145,806.06, not the subsequently determined amount of ₱10,294,721.00 from the DARAB.
The Supreme Court clarified that the sequence of events articulated in the law supports the idea that the deposit of provisional compensation must occur simultaneously with the summary administrative proceedings initiated after the rejection of the initial offer. Additionally, it stressed that while DAR serves an administrative function in evaluating compensati
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Case Background
- The case involves a petition for review on certiorari by the Land Bank of the Philippines (LBP) under Rule 45 of the 1997 Rules of Civil Procedure.
- The petition seeks to reverse the August 8, 2003 Decision of the Court of Appeals (CA) which denied LBP's petition for certiorari and upheld the orders of the Regional Trial Court (RTC) in DAR Case No. 79-2002.
- The private respondent, represented by Alicia Arieta Tan, is the registered owner of an agricultural land approximately 37.1010 hectares, covered by Transfer Certificate of Title No. T-49200.
Relevant Legal Framework
- The land in question was partially covered by the Comprehensive Agrarian Reform Program (CARP) under Republic Act No. 6657, specifically through the Voluntary Offer to Sell (VOS) mechanism.
- The private respondent offered the land to the Department of Agrarian Reform (DAR) at a price of P2,000,000.00 per hectare.
- LBP valued the land at P1,145,806.06 (P76,387.57 per hectare), which was rejected by the private respondent.
Initial Proceedings
- Following the rejection of LBP's offer, LBP deposited the amount of P1,145,806.06 as provisional compensation, as required under Section 16 of RA No. 6657.
- The DAR Adjudication Board (DARAB) conducted administrative proceedings and determined the just compensation to be P10,294,721.00 (P686,319.36 per hectare).
Judicial Actions and Appeals
- LBP filed a motion for reconsideration of the DARAB's decision, which was denied.
- LBP subsequently petitioned the Special Agrarian Court for a judicial determination of just compensation while the private respondent filed a parallel petition against DAR in the same court.
- The Special Agraria