Case Summary (G.R. No. 194168)
Factual Background
The spouses Placido and Clara Orilla owned a parcel of land in Bohol, registered under Transfer Certificate of Title No. 18401, with an area of 23.3416 hectares. In November 1996, the Department of Agrarian Reform (DAR) informed them of the compulsory acquisition of 21.1289 hectares of this land under the Comprehensive Agrarian Reform Law, offering compensation of P371,154.99, based on the valuation conducted by the LBP. The respondents rejected this valuation, prompting a summary hearing before the Provincial DAR Adjudication Board (DARAB), which upheld LBP's valuation. Dissatisfied, the respondents filed a case for the determination of just compensation in the Regional Trial Court of Tagbilaran City, specifically sitting as a Special Agrarian Court (SAC).
Ruling of the Special Agrarian Court
The SAC, after a trial on the merits, issued a decision on November 20, 2000, setting the just compensation at P7.00 per square meter, which amounted to P1,479,023.00 for the acquired land. The SAC further directed the respondents to indemnify the petitioner for appraisal expenses. Following this decision, both parties filed motions regarding the execution of the award, leading to the SAC granting the respondents' motion for execution pending appeal.
Court of Appeals Proceedings
Petitioner subsequently challenged the SAC's decision through a special civil action for certiorari and prohibition before the Court of Appeals (CA). On July 29, 2002, the CA dismissed LBP's petition, affirming the SAC’s order for execution pending appeal as fair and just under the circumstances of RA 6657. The Supreme Court later upheld this decision in G.R. No. 157206.
CA's Decision on the Petitioner’s Appeal
In the ongoing litigation, the CA rendered a decision on April 17, 2009, determining that the SAC's valuation lacked valid legal foundation, thus setting aside the SAC’s ruling and remanding the case for proper determination of just compensation. It noted that prior decisions affirmed the appropriateness of execution pending appeal, honoring the necessity for prompt payment to landowners under agrarian reform principles.
Petitioner’s Arguments Against the CA's Decision
Petitioner LBP filed a Motion for Partial Reconsideration, contending that the annulment of the SAC's judgment rendered it void, and thus, any writ of execution based on such a void decision could not be enforced. The CA, however, denied this motion, clarifying that the validity of the execution had already been settled in prior rulings.
Legal Implications of a Void Judgment
The discussion underscored the nature of void judgments, which are non-existent in the eyes of the law and cannot justify any further legal proceedin
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Case Overview
- The case involves a petition for review on certiorari filed by the Land Bank of the Philippines (petitioner) against spouses Placido and Clara Dy Orilla (respondents).
- The petition challenges the Decision dated April 17, 2009, of the Court of Appeals (CA) in CA-G.R. CV No. 70071 and the subsequent Resolution dated September 30, 2010, which denied the petitioner’s Motion for Partial Reconsideration.
- The case centers around the valuation and compensation concerning the compulsory acquisition of land under the Comprehensive Agrarian Reform Law (RA 6657).
Factual Background
- Respondents are the owners of a parcel of land in Bohol identified as Lot No. 1, 11-12706, with an area of 23.3416 hectares, covered by Transfer Certificate of Title No. 18401.
- In November 1996, the respondents received a Notice of Land Valuation and Acquisition from the Department of Agrarian Reform (DAR), offering P371,154.99 for the compulsory acquisition of 21.1289 hectares of their landholdings.
- The respondents rejected this valuation, leading to a summary hearing conducted by the Provincial Department of Agrarian Reform Adjudication Board (Provincial DARAB), which upheld the petitioner’s valuation.
Proceedings Before the Special Agrarian Court
- Dissatisfied with the Provincial DARAB's affirmation, the respondents filed an action for determination of just compensation in the Regional Trial Court of Tagbilaran City, designated as a Special Agrarian Court (SAC), under Civil Case No. 6085.
- The SAC, in a Decision dated No