Case Summary (G.R. No. 217492)
Antecedent Facts
The controversy originated from the expropriation initiated by BCDA in 2003, targeting two parcels of land previously owned by Belmonte Agro-Industrial Development Corporation (BAIDECO). Both parcels, measuring 2,511 square meters and 1,504 square meters, respectively, were mortgaged to PVB in 1976, foreclosed, and purchased by PVB at a public auction in 1982, after which BAIDECO failed to redeem the properties. In the context of the Comprehensive Agrarian Reform Program (CARP), these properties were awarded to the Saguns, who were farmer-beneficiaries, without notifying PVB.
The Expropriation Process
In 2004, BCDA began expropriation proceedings against the Saguns, which led to their being declared in default due to lack of representation. The RTC granted BCDA a Writ of Possession, and the properties were handed over to BCDA. PVB attempted to intervene in the proceedings, claiming ownership and just compensation due to its prior acquisition of the land.
Ruling of the Regional Trial Court
The Regional Trial Court, in its rulings on August 5, 2011, and later on November 28, 2011, affirmed that BCDA had the right to expropriate the land but concluded that just compensation should be paid to the Saguns. The RTC recognized that the Saguns held better title to the properties due to the issuance of CLOAs. It declared that any compensation due should first satisfy the mortgage lien held by the Landbank of the Philippines (LBP).
Ruling of the Court of Appeals
PVB's subsequent appeal was dismissed by the Court of Appeals, affirming that PVB was not entitled to just compensation. The appellate court reiterated that, by the time of BCDA’s expropriation, the Saguns were the lawful owners of the properties, possessing valid titles and certificates from the DAR. It highlighted the risk of unjust enrichment should PVB also claim compensation for the same properties.
The Supreme Court's Ruling
Upon review, the Supreme Court upheld the findings of the RTC and the Court of Appeals, denying PVB's petition for lack of merit and asserting that any just compensation for the Subject Properties should be awarded to the Saguns as they were the lawful owners at the time of expropriation. The Court emphasized that PVB's prior claim for just compensation under CARP was separate and should not entitle them to compensation in the SCTEX expropriation, as the properties had been taken under the CARP before the later expropriation occurred.
Conclusion on Just Compensation
The Supreme Court ruled that compensation due for the properties should adhere strictly to the context in which they were acquired. The Court noted that just compensation aims to reflect the value of the property at the time of its taking
...continue readingCase Syllabus (G.R. No. 217492)
Overview of the Case
- The case involves a petition for review on certiorari from the Philippine Veterans Bank (PVB) challenging the decisions of the Court of Appeals (CA) regarding just compensation for properties expropriated by the Bases Conversion and Development Authority (BCDA).
- The primary issue is whether the just compensation should be awarded to PVB or to the farmer-beneficiaries, Marcelo Sagun and Edner Sagun.
Antecedent Facts
- In 2003, BCDA initiated expropriation proceedings for lands necessary for the Subic-Clark-Tarlac Expressway (SCTEX) project.
- The properties in question were originally owned by Belmonte Agro-Industrial Development Corporation (BAIDECO), which mortgaged the properties to PVB.
- PVB foreclosed on the mortgages and acquired the properties through public auction in 1982 after BAIDECO failed to redeem them.
- The properties were later covered by the Comprehensive Agrarian Reform Program (CARP) and distributed to Marcelo and Edner Sagun, who received Certificates of Land Ownership Award (CLOA) and Transfer Certificates of Title (TCT).
Expropriation under CARP
- The CARP, through Republic Act No. 6657, mandates the redistribution of agricultural lands to farmer-beneficiaries.
- LBP deposited advance payments to the registered landowners, leading to the issuance of CLOAs and TCTs to the Saguns without notifying PVB.
- PVB, upon discovering the distribution of the properties, initially sought to nullify the CLOAs and TCTs but later withdrew this action based on jurisdictional issues.