Case Summary (G.R. No. 170685)
Factual Antecedents
The Land Bank of the Philippines (LBP) serves as a government financial institution for the Comprehensive Agrarian Reform Program (CARP). Enrique Livioco owned approximately 30.6329 hectares of sugarland in Mabalacat, Pampanga, which he offered for acquisition under CARP at PHP 30.00 per square meter, culminating in a total claim of PHP 9,189,870. Following this offer, LBP valued the property at PHP 3.21 per square meter, amounting to PHP 827,943.48, and informed Livioco about this valuation, with the funds held in trust pending the submission of necessary ownership documents. Livioco did not fulfill these requirements, prompting LBP to issue a certification of compensation earmarking the specified amount. Two years later, he sought a reevaluation based on an alleged increase in property value but was informed of a perfected sale.
Judicial Proceedings
The Department of Agrarian Reform (DAR) took possession of the land and awarded Certificates of Land Ownership Award (CLOAs) to farmer-beneficiaries in 1994. Livioco’s attempts to recover his property through litigation were unsuccessful as the Court of Appeals upheld the validity of the CLOAs. A subsequent petition for reconveyance filed in 1998 was also dismissed due to prior adjudications asserting the legitimacy of the property’s acquisition.
Valuation Disputes
As LBP amended its valuation of the property over several years, Livioco contended that the agricultural land had transitioned into a residential area due to surrounding developments. He presented evidence to support a market valuation of PHP 700.00 per square meter, citing testimonials and local zoning classifications. LBP, however, maintained that the valuation must reflect its acquisition for agricultural use according to legislative guidelines. This sparked a legal battle that culminated in a trial court judgment establishing the compensation at PHP 700.00 per square meter, leading to appeals from LBP.
Ruling of the Regional Trial Court
The Regional Trial Court (RTC) determined that just compensation was justified at a valuation of PHP 700.00 per square meter based on the evidence presented by Livioco, contrasting it with LBP's lack of supporting documentation for its lower valuation. LBP sought reconsideration, arguing that the RTC failed to adequately consider the statutory requirements outlined in Section 17 of RA 6657.
Ruling of the Court of Appeals
The Court of Appeals upheld the RTC's decision by emphasizing that all relevant factors, including tax declarations and current property uses, were considered in determining just compensation. It affirmed that the taking of Livioco’s property coincided with various factors, including changes in socio-economic conditions brought about by the Mt. Pinatubo eruption.
Supreme Court's Analysis
Upon review, the Supreme Court identified errors in both the RTC and the Court of Appeals regarding the characterization of Livioco’s property as residential rather than agricultural at the time of taking. The Court underscored that the fair market value should reflect the property’s use as agricultural land, emphasizing that without a proper conversion approval from the DAR, the lower courts had no legal bas
...continue readingCase Syllabus (G.R. No. 170685)
Background of the Case
- The case involves a Petition for Review under Rule 45, contesting the August 30, 2005 Decision of the Court of Appeals (CA) regarding just compensation for land expropriated under the Comprehensive Agrarian Reform Law (CARP).
- The petitioner, Land Bank of the Philippines (LBP), challenges the valuation of the respondent, Enrique Livioco's, property that was taken for agrarian reform purposes.
- The CA's decision affirmed the Regional Trial Court (RTC) of Angeles City’s ruling, which established the compensation at P700.00 per square meter for the property.
Factual Antecedents
- Livioco owned 30.6329 hectares of sugarland in Mabalacat, Pampanga, which he offered to the Department of Agrarian Reform (DAR) for acquisition at P30.00 per square meter in 1987-1988.
- The LBP set the compensation at P3.21 per square meter, totaling P827,943.48 for 26 hectares, but Livioco did not act on this valuation.
- DAR took possession of Livioco's property in 1994 and awarded Certificates of Land Ownership Award (CLOAs) to farmer-beneficiaries.
- Livioco's attempts to contest the CLOAs, including a quieting of title action, were unsuccessful.
Legal Proceedings
- Livioco filed a petition for judicial determination of just compensation in December 2001, asserting that the land's value had appreciated due to its location becoming predominantly residential.
- He presented various certifications to support his claim for a higher valuation, including evidence from municipal and housing authorities, and appraisals suggesting values up to P800.00 per square meter.
- LBP defended its original valuation based on agricultural use, arguing that the property should not be valued as residential land since it was acquired for agricultural purposes.