Case Summary (G.R. No. 240230)
Factual Antecedents
In July 2000, the respondents voluntarily offered to sell their land to the Department of Agrarian Reform (DAR) under the provisions of R.A. No. 6657. Following a field investigation, the DAR determined that only 21.6101 hectares were subject to acquisition. The LBP initially valued this portion at P304,735.09, later adjusting the offer to P298,101.21 after deducting the value of a 0.3643-hectare legal easement. However, the respondents rejected this valuation and escalated the matter to the DAR Provincial Agrarian Reform Adjudicator (PARAD) for a determination of just compensation.
The PARAD’s Ruling
On January 8, 2002, PARAD Manuel M. Capellan assessed the just compensation for the property at P928,330.17. The substantial difference from the LBP’s offer arose from the PARAD’s reliance on an average selling price of P16.00 per kilogram of copra, compared to the LBP’s figure of P5.86. This valuation was integral as it used the Capitalized Net Income (CNI) methodology, critical for determining just compensation.
The RTC-SAC's Ruling
The LBP sought to contest the PARAD ruling in the Regional Trial Court, which acted as a Special Agrarian Court (RTC-SAC). In a decision dated August 15, 2003, the RTC-SAC upheld the PARAD valuation, finding it fair and just based on multiple factors, including the land's yield, geographical condition, proximity to markets, improvements, and comparable sales. Subsequent motions for reconsideration filed by the LBP were denied.
The Court of Appeals’ Ruling
Upon appeal, the Court of Appeals, in its ruling dated September 29, 2005, affirmed the RTC-SAC’s decision. The CA rejected the LBP’s assertions that the RTC-SAC had erred in its valuation method. It noted that both the LBP and the PARAD used the same formula under DAR Administrative Order No. 5, series of 1998. The CA deemed the LBP’s valuation unrealistic in light of the prevailing conditions, as determined by the RTC-SAC.
The Petition for Review
In seeking a review from the Supreme Court, the LBP reiterated its position that the average selling price of P5.86 per kilogram of copra should have been the basis for determining just compensation, as set by regulatory guidelines.
Court's Ruling
The Supreme Court denied the LBP’s petition, emphasizing that the determination of just compensation must consider the factors outlined in Section 17 of R.A. No. 6657. The court reaffirmed the importance of applying the correct formulas as dictated by the law, firmly establishing that the differing valuations between the LBP and the PARAD stemmed from factual determinations regarding
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Case Background
- This case involves a petition for review on certiorari filed by the Land Bank of the Philippines (LBP) against the heirs of Juan Lopez.
- The case originated from the September 29, 2005 decision of the Court of Appeals (CA) in C.A. G.R. SP No. 80918.
- The LBP also contests the CA's December 23, 2005 resolution denying its motion for reconsideration.
- The CA dismissed the LBP's appeal for lack of merit.
Factual Antecedents
- The heirs of Juan Lopez owned a coconut land parcel in San Vicente, Castilla, Sorsogon, measuring 23.1301 hectares, covered by Original Certificate of Title No. P-32.
- In July 2000, Monserrat L. Marchan, on behalf of her co-respondents, voluntarily offered to sell the land to the Department of Agrarian Reform (DAR) under Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988).
- After a field investigation, only 21.6101 hectares were found subject to acquisition.
- The LBP valued the property at P14,101.51 per hectare, totaling P304,735.09, later reduced to P298,101.21 after deducting the value of a 0.3643-hectare legal easement.
- The respondents rejected the LBP's offer and elevated the matter to the DAR Provincial Agrarian Reform Adjudicator (PARAD) for just compensation determination.
The PARAD's Ruling
- On January 8, 2002, PARAD Manuel M. Capellan set the just compensation for the 21.6101 hectares at P928,