Meneses v. Secretary of Agrarian Reform
REITERATIONFacts
The Antecedents: Petitioners, as co-owners of a 60.8544-hectare irrigated rice land in Bulacan, registered in their grandparents' names, initiated a legal dispute concerning the determination and payment of just compensation for their property. This land was distributed to farmer-beneficiaries in 1972 under Presidential Decree No. 27 (P.D. No. 27). The core of the dispute lies in the petitioners' claim that they have not received any payment or rentals for the land since its distribution, despite titles being issued to the farmer-beneficiaries, and they assert the property's fair market value to be P6,000,000.00. Procedural History: The petitioners' legal journey began with a complaint filed in the Regional Trial Court (RTC) of Bulacan in 1993. The RTC initially dismissed the case for lack of cause of action, stating that the determination of just compensation must first be filed with the Department of Agrarian Reform (DAR). Following a motion for reconsideration, the RTC suspended proceedings pending primary determination of just compensation. Subsequently, the petitioners filed a complaint with the DAR Adjudication Board (DARAB), which dismissed it for lack of jurisdiction. The case returned to the RTC, which appointed commissioners, dissolved them, and eventually dismissed the complaint in 1998, ruling that just compensation should be based on the value at the time of taking in 1972. The petitioners appealed to the Court of Appeals (CA), which dismissed their appeal, and a subsequent motion for reconsideration was denied due to late filing. This led to the present petition before the Supreme Court. The Petition: The petitioners seek a review on certiorari of the Court of Appeals' decision, arguing that it was rendered contrary to law and Supreme Court decisions, and that the CA sanctioned a departure from usual judicial proceedings. They contend that the CA erred in sustaining the propriety of a motion for judgment on the pleadings and in affirming the RTC's dismissal of their case, especially since no initial valuation by the DARAB appeared to have been made. The petitioners also argue that the CA erred in ruling that just compensation should be based on the value at the time of taking (October 21, 1972) under P.D. No. 27, asserting that the more recent law, Republic Act No. 6657, should govern. They further argue that even if P.D. No. 27 applied, the RTC should not have dismissed the complaint but proceeded to determine just compensation. The petition highlights the prolonged delay in receiving compensation and the conflicting rulings from lower courts and agencies, leading to a situation where petitioners have been deprived of the property's value for over 30 years.
Issue(s)
Whether the Court of Appeals erred in sustaining the propriety of the motion for judgment on the pleadings filed by respondents. Whether the Court of Appeals erred in affirming the Regional Trial Court's ruling that just compensation should be based on the value of the property at the time of taking (October 21, 1972) under Presidential Decree No. 27. Whether the Court of Appeals erred in affirming the Regional Trial Court's dismissal of the complaint for determination and payment of just compensation.
Ruling
The petition is GRANTED. The Decision dated May 30, 2002 and Resolution dated December 9, 2002 rendered by the Court of Appeals in CA-G.R. CV No. 60355 are REVERSED and SET ASIDE. The records of this case are ordered REMANDED to the Regional Trial Court (RTC) of Bulacan, Branch 13, for further proceedings with deliberate dispatch and in accordance with the Court's discussion in this Decision.
Ratio Decidendi
On the propriety of the motion for judgment on the pleadings: The Court finds that the Court of Appeals erred in sustaining the propriety of the motion for judgment on the pleadings. Rule 34, Section 1 of the Rules of Court provides that a judgment on the pleadings is proper when an answer fails to render an issue or otherwise admits the material allegations of the adverse party's pleading. In this case, the separate Answers filed by the respondents definitely tendered issues, as they made specific denials of the material allegations in the complaint and asserted affirmative defenses. Moreover, it was erroneous for the RTC to require the filing of such a motion and for the LBP and DAR Secretary to file the same, as they were neither plaintiffs nor counter-claimants. The Court clarified that what the RTC likely meant was a motion for summary judgment, which can be filed by either a claimant or a defending party when there is no genuine issue regarding any material fact, except as to the amount of damages. On the applicable law for determining just compensation: The Court finds that the Court of Appeals erred in sustaining the RTC ruling that just compensation should be based on the value of the property at the time of taking, October 21, 1972, under P.D. No. 27. While the case of Gabatin v. Land Bank of the Philippines supported valuation at the time of taking, the more recent case of Land Bank of the Philippines vs. Natividad categorically ruled that the seizure of the landholding takes effect upon the payment of just compensation, not on the date of effectivity of P.D. No. 27. Under Section 17 of R.A. No. 6657, several factors are considered in determining just compensation, including cost of acquisition, current value of like properties, nature, use, income, sworn valuation, tax declarations, and assessments. The Court deemed it more equitable to apply the ruling in the Natividad case, as the agrarian reform process remained incomplete due to the delay in settling just compensation. Considering the passage of R.A. No. 6657 before the completion of this process, just compensation should be determined and the process concluded under R.A. No. 6657, with P.D. No. 27 and E.O. No. 228 having only suppletory effect. It would be inequitable to determine just compensation based on P.D. No. 27 and E.O. No. 228 given the DAR's failure to determine it for a considerable length of time. On the dismissal of the complaint: The Court sustains petitioners' contention that the CA erred in ruling that the RTC correctly dismissed their complaint. Even assuming that P.D. No. 27 applied, the RTC should not have simply dismissed the complaint after resolving the issue of which law should apply. Instead, it should have proceeded to determine the just compensation due to petitioners. The records show that the petitioners' case was shuttled between the RTC and the DARAB, with each dismissing the complaint on jurisdictional grounds. This left petitioners without recourse, which is iniquitous considering their property was expropriated long ago and its fruits enjoyed by others. Therefore, the case should be remanded to the RTC for the final determination of just compensation.
Main Doctrine
The determination of just compensation for lands acquired under Presidential Decree No. 27, when the agrarian reform process remains incomplete due to the delay in settling the compensation, should be governed by Republic Act No. 6657, considering the passage of the latter law before the completion of the process. Furthermore, a motion for judgment on the pleadings is improper when the respondent's answer tenders issues and the moving party is neither a claimant nor a counter-claimant.