Case Summary (G.R. No. 93661)
Summary of Facts
The case involves the proposed sale of the Garchitorena estate, consisting of approximately 1,887.819 hectares in Garchitorena, Camarines Norte. A Contract to Sell was executed between Sharp International Marketing and the United Coconut Planters Bank (UCPB) on April 27, 1988, allowing Sharp to acquire the property for PHP 3,183,333.33. Sharp, before even owning the land, offered to sell it to the Government for PHP 56 million, later increasing the price to PHP 65 million. The sale was subsequently processed by various government agencies, leading to a recommended acquisition price of PHP 67 million.
Execution of Sale and Government Proceedings
On December 1, 1988, a Deed of Absolute Sale was executed between UCPB and Sharp, transferring the property to Sharp. Following this, on December 29, 1988, a directive was issued by DAR Secretary Philip Ella Juico for the Land Bank of the Philippines (LBP) to acquire the estate for PHP 62,725,077.29, confirming the arrangement for payment to Sharp. The following events involved the LBP's hesitance due to the significant disparity in land valuation — having acquired it one month prior for only PHP 3 million.
Legal Contentions
Sharp filed a petition for mandamus against the DAR and LBP, demanding compliance with the contract. The Court of Appeals ruled against Sharp, stating that the LBP's signing of the Deed of Absolute Sale was not merely a ministerial act but required the exercise of discretion and judgment due to the substantial public funding involved. The appellate court found that the acquisition price was unconscionable and that the process did not adhere to established guidelines for just compensation under the Comprehensive Agrarian Reform Law.
Rulings of the Court of Appeals
The Court of Appeals determined that the devolvement of authority to determine just compensation extends beyond the DAR Secretary and necessitates LBP’s approval. The ruling established that, not only was the assessed compensation excessive, but the transaction itself was rendered null and void for violating existing statutes concerning land acquisition and compensation protocols.
Supreme Court Analysis
The Supreme Court affirmed the Court of Appeals' ruling, emphasizing that mandamus could not compel the LBP to perform a discretionary act, especially regarding the appro
...continue readingCase Syllabus (G.R. No. 93661)
Background of the Case
- The case revolves around the aborted sale of the Garchitorena estate to the Government under the Comprehensive Agrarian Reform Program (CARP).
- The petitioner, Sharp International Marketing, demanded that the private respondents (Land Bank of the Philippines and Deogracias Vistan) sign a contract of sale to make it a perfected agreement.
- The focus of the case is the decision of the Court of Appeals that denied this demand.
Details of the Property and Transaction
- The Garchitorena estate consists of eight parcels of land in Camarines Norte, totaling 1,887.819 hectares.
- On April 27, 1988, United Coconut Planters Bank (UCPB) sold the property to Sharp International Marketing for P3,183,333.33, which was to be converted into a Deed of Absolute Sale upon full payment.
- Sharp, prior to acquiring the land, offered to sell it to the government for P56,000,000.00, later increasing the offer to P65,000,000.00.
- Various government agencies processed this offer, leading to a recommendation for acquisition at approximately P67,000,000.00.
Execution of Sale and Subsequent Developments
- A Deed of Absolute Sale was finalized between UCPB and Sharp on December 1, 1988, and registered on December 6, 1988.
- On December 27, 1988, a Compensation Clearing Committee was formed by the Department of Agrarian Reform (DAR) and Land Bank of the Philippines to expedite the acquisition process.
- DAR Secretary