Case Summary (G.R. No. 172551)
Factual Background
Upon coverage under CARP, LBP preliminarily valued Yatco’s land at ₱1,126,132.89. Dissatisfied, Yatco invoked summary administrative proceedings before the DAR Provincial Adjudicator, which computed just compensation at ₱16,543,800. LBP then petitioned the RTC-SAC for judicial determination.
RTC-SAC’s Valuation
The trial court adopted the valuation (₱200.00 per sq. m.) set in two earlier civil expropriation cases handled by other RTC branches. It rejected LBP’s evidence for noncompliance with RA 6657 Section 17 factors and DAR AO 5-98 procedures. LBP’s motion for reconsideration was denied.
Court of Appeals’ Decision
The CA dismissed LBP’s appeal, holding that:
- The civil-case land parcels were identical to the agrarian case property.
- Branch 36’s valuation arose from duly appointed commissioners after proper land inspection.
- Just compensation is a judicial function, and the RTC-SAC’s factual and legal basis was persuasive.
Issue on Review
Whether the RTC-SAC properly determined just compensation by exclusively relying on valuations from civil expropriation cases instead of applying the statutory factors and DAR formula under RA 6657 and DAR AO 5-98.
Supreme Court’s Jurisdictional Analysis
Under Rule 45, the Supreme Court’s review is confined to questions of law. The issue—whether reliance on prior civil-case valuations complied with the statutory scheme—is legal in nature and thus reviewable without re-examining evidence.
Judicial Function in Determining Just Compensation
Section 57, RA 6657, vests RTC-SACs with exclusive jurisdiction over agrarian just-compensation petitions. Determination of just compensation is a judicial act guided by statutory factors and implementing rules.
Mandatory Application of RA 6657 Section 17 and DAR AO 5-98
Section 17 mandates consideration of acquisition cost, comparable sales, capitalized net income, market value per tax declaration, and additional social and economic factors. DAR AO 5-98 codifies these into a basic formula and alternative computations when some factors are absent. Uniform application ensures fair approximations of real property value. Deviations from the formula must be explained; wholesale disregard constitutes grave abuse of discretion.
Error in Valuation and Evidence
The RTC-SAC:
- Failed to indicate which formula or statutory factors it applied.
- Did not assess the tax-declaration market value under DAR AO 5-98’s MV × 2 provision.
- Offered no explanation for adopting Branch 36’s P20.00/sq. m. valuation or for the P200.00/sq. m. outcome.
- Did not conduct an independent computation or appoint commissioners under Section 58, RA 6657, to address evidentiary gaps.
Inapplicability of Civil-Case Valuations
Civil Case Nos. 2259-95-C and 2326-96-C involved NA
...continue readingCase Syllabus (G.R. No. 172551)
Factual Background
- Yatco Agricultural Enterprises was the registered owner of a 27.5730-hectare agricultural parcel in Barangay Mabato, Calamba, Laguna (TCT No. T-49465).
- On April 30, 1999, the land was placed under the Comprehensive Agrarian Reform Program (CARP) by Second Notice of Coverage.
- Executive Order No. 405 tasked the Land Bank of the Philippines (LBP) with valuing agrarian reform lands; LBP valued the property at ₱1,126,132.89.
- Yatco contested this valuation before the DAR Provincial Agrarian Reform Adjudicator (PARAD), which computed just compensation at ₱16,543,800.00 using the MV × 2 formula based on the submitted tax declaration.
- LBP did not seek reconsideration of the PARAD ruling and instead filed a petition for judicial determination of just compensation with the RTC-SAC on February 6, 2002.
Procedural History
- The Regional Trial Court, Branch 30, San Pablo City, acting as a Special Agrarian Court (RTC-SAC), conducted Agrarian Case No. SP-064(02).
- RTC-SAC fixed just compensation at ₱200.00 per square meter by adopting valuations in Civil Case Nos. 2259-95-C (Branch 36) and 2326-96-C (Branch 35).
- RTC-SAC denied LBP’s motion for reconsideration.
- LBP appealed to the Court of Appeals (CA) under Rule 42; the CA dismissed the appeal and denied reconsideration in its resolution of May 3, 2006.
- LBP filed a Rule 45 petition for review on certiorari before the Supreme Court on June 20, 2006.
RTC-SAC Decision
- Adopted prior valuations of ₱20.00/sqm from Branch 36 (1997) and Branch 35 (2001), yet set compensation at ₱200.00/sqm without explaining the computation.
- Disregarded LBP’s evidence for purported failure to follow prescribed procedures and to consider factors in Section 17 of R.A. 6657.
- Denied LBP’s motion for reconsideration.
Court of Appeals Ruling
- Affirmed RTC-SAC’s valuation as based on the very same parcels and on factual findings in Branches 35 and 36.
- Emphasized that determination of just compensation is a judicial function and found no grave abuse of discretion.
- Denied LBP’s m