GR 176692; (June, 2012) (Digest)
G.R. No. 176692 ; June 27, 2012
Land Bank of the Philippines, Petitioner, vs. Veronica Atega Nable, Respondent.
FACTS
Respondent Veronica Atega Nable owned 129.4615 hectares of agricultural land in Butuan City. In 1993, the Department of Agrarian Reform (DAR) compulsorily acquired 127.3365 hectares under the Comprehensive Agrarian Reform Program (CARP). Petitioner Land Bank of the Philippines (LBP) valued the property at ₱5,125,036.05, which Nable rejected. The DAR Adjudication Board affirmed LBP’s valuation.
Nable filed a petition for judicial determination of just compensation before the Regional Trial Court (RTC), sitting as a Special Agrarian Court (SAC). The RTC, considering the report of a board of commissioners and other evidence, fixed just compensation at ₱26,523,180.00. The Court of Appeals (CA) affirmed the RTC’s decision but modified the valuation to ₱36,159,855.00, ordering LBP to pay the balance after deducting its initial valuation.
ISSUE
The core issue is whether the CA and the RTC erred in their determination of just compensation by allegedly disregarding the formula under Section 17 of RA 6657 and DAR Administrative Orders, and by considering evidence not strictly aligned with those parameters.
RULING
The Supreme Court denied LBP’s petition and affirmed the CA’s decision. The Court held that the determination of just compensation is a judicial function, and while Section 17 of RA 6657 and the related DAR Administrative Orders provide the framework, they are not strictly binding formulas that courts must apply with absolute rigidity. The SAC has the discretion to consider all relevant factors to arrive at a fair and equitable valuation that truly reflects the property’s value at the time of taking.
The Court found that the RTC did not disregard the legal parameters. It considered the required factors—such as the property’s nature, actual use, income, and sworn valuation by the owner—but reasonably exercised its judgment in weighing the evidence, including the commissioners’ report. The commissioners conducted an ocular inspection and considered various data, which the RTC properly evaluated. LBP’s failure to timely object to the commissioners’ report during the proceedings precluded it from raising hearsay objections on appeal. The award of interest was also proper, as just compensation earns interest from the time of taking until full payment to compensate for the delay.