GR 194168; (February, 2013) (Digest)
G.R. No. 194168 ; February 13, 2013
LAND BANK OF THE PHILIPPINES, Petitioner, vs. SPOUSES PLACIDO and CLARA DY ORILLA, Respondents.
FACTS
Respondents Spouses Orilla owned agricultural land compulsorily acquired under the Comprehensive Agrarian Reform Program (CARP). Petitioner Land Bank of the Philippines (LBP) valued the land at ₱371,154.99, which the respondents rejected. The Provincial DARAB affirmed LBP’s valuation. Respondents then filed for just compensation before the Regional Trial Court (RTC) sitting as a Special Agrarian Court (SAC). The SAC fixed just compensation at ₱7.00 per square meter, totaling ₱1,479,023.00, and ordered LBP to deposit the amount.
LBP appealed the SAC decision. Meanwhile, the respondents moved for execution pending appeal, which the SAC granted. This order was affirmed by the Court of Appeals (CA) and subsequently by the Supreme Court in a prior petition ( G.R. No. 157206 ). Separately, on the main appeal regarding valuation, the CA set aside the SAC decision and remanded the case for proper determination of just compensation, finding the SAC’s ₱7.00/sq.m. valuation lacked sufficient basis. LBP then filed the instant petition, arguing that with the remand, the executed amount based on the vacated SAC decision must be returned.
ISSUE
Whether the remand of the case to the SAC for proper determination of just compensation invalidates the execution pending appeal and obligates the respondents to return the withdrawn compensation.
RULING
No. The Supreme Court affirmed the CA’s decision to remand the case but upheld the validity of the execution pending appeal and denied LBP’s claim for restitution. The legal logic is twofold. First, the principle of “prompt payment” is integral to the constitutional guarantee of just compensation. The Court emphasized that compensation is not just if the property owner is deprived of land for years without payment. The execution pending appeal served this principle, as the respondents had already been deprived of their property.
Second, the grant of execution pending appeal was a final ruling on that incidental matter, which attained finality when affirmed by the Supreme Court in G.R. No. 157206 . This finality is not nullified by the subsequent remand of the main case for recalculation of the final just compensation figure. The amount released under the executed order is considered a provisional payment. The remand merely allows for a recomputation; it does not retroactively invalidate the provisional release. Therefore, LBP is not entitled to a refund. The Court ordered LBP to release its initial valuation of ₱371,154.99 to the respondents, without prejudice to the SAC’s eventual recomputation, which would account for any difference.