GR 176410; (September, 2010) (Digest)
G.R. No. 176410 ; September 1, 2010
LAND BANK OF THE PHILIPPINES, Petitioner, vs. CONRADO O. COLARINA, Respondent.
FACTS
Respondent Conrado O. Colarina, owner of three agricultural parcels totaling 97.2047 hectares, voluntarily offered them for sale under the Comprehensive Agrarian Reform Program. The Land Bank of the Philippines (LBP), as the financial intermediary, assessed the properties. It excluded 40 hectares for having a slope over 18%, as per Section 10 of R.A. No. 6657 , and valued the remaining 57.2047 hectares using the formula under DAR Administrative Orders. Colarina rejected LBP’s valuation of approximately ₱10,681.82 per hectare, contending it was too low.
Colarina elevated the matter to the Provincial Agrarian Reform Adjudicator, which affirmed LBP’s valuation. Dissatisfied, he filed a complaint for judicial determination of just compensation before the Regional Trial Court (RTC) sitting as a Special Agrarian Court (SAC). The SAC, after trial, fixed just compensation at ₱45,000.00 per hectare for the entire 97.2047 hectares, ordering LBP to pay the total value plus interest. The Court of Appeals affirmed this decision, prompting LBP’s petition for review.
ISSUE
Whether the SAC correctly determined the just compensation for the subject agricultural lands.
RULING
The Supreme Court denied the petition and affirmed the SAC’s determination. The Court reiterated that the determination of just compensation is a judicial function. While DAR administrative orders provide the basic formulas, courts are not strictly bound by them and must consider all relevant factors to arrive at a fair and equitable valuation, as mandated by Section 17 of R.A. No. 6657 and its implementing rules.
The Court found that the SAC correctly exercised its discretion. It considered the testimonies and evidence presented, including the appraisal of Colarina’s expert witness, Carlito Oliva, who valued the land at ₱49,201.148 per hectare using the productivity approach. The SAC also noted that LBP’s own witness admitted the valuation could reach ₱30,000 per hectare if based on comparable sales. The SAC’s final award of ₱45,000 per hectare was a reasoned conclusion based on the evidence on record, including the land’s nature, actual use, and potential income. The Court emphasized that the trial court, having observed the witnesses firsthand, is in the best position to weigh evidence. It found no reason to deviate from the SAC’s factual findings, which were affirmed by the Court of Appeals.