GR 221313; (December, 2019) (Digest)
G.R. No. 221313 , December 05, 2019
LAND BANK OF THE PHILIPPINES, PETITIONER, VS. EUGENIA UY, ROMUALDO UY, JOSE UY, RENATO UY, ARISTIO UY, AND TERESITA UY-OLVEDA, RESPONDENTS.
FACTS
Respondents owned agricultural land in Mulanay, Quezon placed under the Comprehensive Agrarian Reform Program (CARP) in 1995. Petitioner Land Bank initially valued the property at P516,484.84, later updated to P1,048,635.38 under DAR Administrative Order No. 5, Series of 1998 (DAR A.O. No. 5-1998), which respondents rejected. After summary administrative proceedings affirmed the valuation, respondents filed a complaint for determination of just compensation before the Regional Trial Court (RTC) of Lucena City, sitting as a Special Agrarian Court. The RTC, in its January 23, 2006 Decision, directed petitioner to recompute just compensation for the portion devoted to coconut production based on DAR A.O. No. 5-1998, using data on local coconut population from the Philippine Coconut Authority (PCA) and the Assessor’s Office. The PCA certification stated an average of 160 coconut trees per hectare. Petitioner appealed to the Court of Appeals (CA), which in a June 29, 2007 Decision declared the PCA certification unreliable and remanded the case to the RTC to determine the number of coconut trees anew, with the appointment of commissioners. The CA’s remand order specifically affirmed the rest of the RTC’s factual findings, which were undisputed, including the valuation of the cornland portion. Commissioners later treated the entire property as coconut land, valuing it at P82,500.00 per hectare with 160 trees per hectare, for a total of P3,093,370.50. The RTC, in a February 26, 2010 Order, recalculated and set just compensation at P2,877,040.00 for the entire 35.963-hectare property, treated as entirely coconut land, minus the initial payment. Petitioner moved for reconsideration, arguing for separate valuations for the coconut and corn portions and a lower valuation. The RTC denied the motion. Petitioner appealed to the CA, which in its December 11, 2014 Decision modified the RTC’s order, ruling the entire property was coconut land and estopping petitioner from claiming otherwise, but adjusting the valuation to P2,339,892.32 based on DAR A.O. No. 5-1998, with interest. Petitioner filed this Petition for Review.
ISSUE
1. Whether the CA gravely abused its discretion in ruling that the entire subject property was coconut land.
2. Whether estoppel will lie against the petitioner.
3. Whether the petitioner should be made liable to pay interest on the just compensation.
RULING
1. The CA erred in finding the entire landholding to be coconut land and in declaring petitioner estopped from refuting this finding. The consistency of petitioner’s position that the land was mixed-use (coconut and corn) was clear in the proceedings below, through its comments, oppositions, motion for reconsideration, and formal offer of evidence. The CA’s own June 29, 2007 remand order in CA-G.R. SP No. 93647 had conclusively established that the property was planted with both corn and coconut, affirming the uncontested original ruling on the cornland’s breadth and valuation. The remand directive was limited to determining the coconut tree population on the 17-hectare coconut portion only. The nature and character of the land at the time of taking is the principal criterion for determining just compensation.
2. Estoppel does not lie against petitioner. Petitioner consistently asserted the mixed nature of the landholding and never admitted it was purely coconut-producing. Its actions in the proceedings did not constitute estoppel.
3. Petitioner is liable to pay interest on the just compensation. The constitutional guarantee of just compensation requires payment of interest when there is a delay, calculated from the time of taking until full payment. The Court modified the interest rate: twelve percent (12%) per annum from the time of taking in 1995 until June 30, 2013, and six percent (6%) per annum from July 1, 2013 until full payment.
The Court PARTIALLY GRANTED the Petition. It SET ASIDE the CA December 11, 2014 Decision. The case was REMANDED to the RTC, sitting as a Special Agrarian Court, to compute just compensation separately for the 17-hectare coconut land and the 10.5975-hectare cornland, strictly applying the formula in DAR A.O. No. 5-1998, using the commissioners’ finding of 212 coconut trees per hectare for the coconut land and the uncontested valuation for the cornland. The total just compensation shall earn legal interest at 12% per annum from 1995 until June 30, 2013, and at 6% per annum thereafter until full payment.
