Tabuena v. Land Bank of the Philippines
REITERATIONFacts
The Antecedents: Petitioners, heirs of Roque F. Tabuena and others, were owners of Lot No. 6183, an irrigated riceland. A portion of this lot, 26.2585 hectares, was brought under the coverage of P.D. No. 27 by the Department of Agrarian Reform (DAR), which set its value at P105,572.48. Petitioners alleged this valuation was in contravention of their right to just compensation. Procedural History: The Regional Trial Court (RTC) of Sorsogon City, Branch 52, initially referred the case to the DARAB for initial valuation but later fixed the just compensation at P4,855,000.00. The RTC ordered the Land Bank of the Philippines (LBP) to pay this amount, less any previous payments. Both DAR and LBP appealed to the Court of Appeals (CA). The CA reversed the RTC decision, dismissing the complaint for determination and payment of just compensation. The CA ruled that the Deed of Assignment of Rights, which petitioners failed to deny under oath, constituted an admission of its genuineness and due execution, and that petitioners had been fully compensated. The CA also found that the cause of action had prescribed and that the valuation should be based on the time of taking. The Petition: Petitioners sought review of the CA's decision, arguing that the Deed of Assignment of Rights should not have been admitted as evidence since it was not formally offered, and that they executed it under duress.
Issue(s)
Whether the Court of Appeals erred in admitting the Deed of Assignment of Rights despite it not being formally offered as evidence. Whether petitioners are estopped from assailing the validity of the Deed of Assignment of Rights, and whether petitioners' claim for an increase in the valuation of the property has basis. Whether laches has set in due to petitioners' inaction. Whether the Land Bank of the Philippines has locus standi to appeal the RTC decision independently of the DAR. Whether the valuation should be based on the time of taking.
Ruling
The petition is denied. The Decision of the Court of Appeals, which reversed and set aside the RTC decision and dismissed the complaint for determination and payment of just compensation, is affirmed.
Ratio Decidendi
On the admissibility of the Deed of Assignment of Rights: While courts generally cannot consider evidence not formally offered, this rule has been relaxed when the evidence, though not formally offered, has been identified by testimony and incorporated into the records. In this case, the Deed of Assignment of Rights was set up as an affirmative defense in LBP's Answer and was incorporated as an annex. Petitioners failed to question its existence or due execution and, in fact, acknowledged receipt of a portion of the compensation and admitted its appearance as an encumbrance on their title. Their failure to specifically deny it under oath constituted a judicial admission of its genuineness and due execution, pursuant to Sections 7 and 8, Rule 8 of the Rules of Court. On estoppel and the basis for the claim for increased valuation: By virtue of the Deed of Assignment of Rights executed by petitioners, wherein they acknowledged receipt of the full compensation for their property and assigned their rights to LBP, their claim for an increase in valuation has no basis. The Deed explicitly stated that LBP had satisfactorily paid and settled the net cost or value of the landholdings in cash and bonds, which petitioners acknowledged to have received to their full satisfaction. This extinguished LBP's obligation, and petitioners were estopped from assailing the validity of the deed, absent any evidence of compulsion or duress. On laches: Laches has set in due to petitioners' inaction for more than 20 years to assail the due execution of the Deed of Assignment of Rights. Laches is defined as the failure or neglect for an unreasonable and unexplained length of time to do what could have been done earlier. The subject property was acquired under P.D. No. 27 (effective October 21, 1972), the Deed was executed on October 10, 1979, and the action for just compensation was filed only on September 28, 2000. All elements of laches are present, warranting the presumption that petitioners abandoned or declined to assert their right. On the locus standi of LBP: LBP is an indispensable party in actions for the determination of just compensation in agrarian reform cases because it plays a crucial role in the valuation and compensation process. As an agency vested with primary responsibility and authority in this regard, it can file an appeal independently of the DAR, even if the DAR's petition for review was dismissed. The absence of LBP's participation would prevent a judicial determination of just compensation. On the valuation and time of taking: The Deed of Assignment of Rights clearly indicated the amounts paid in cash and bonds, stating that this settlement was in full compensation. Furthermore, in expropriation proceedings, the just compensation is computed based on the value of the land at the time of the taking, not at the time of the rendition of the judgment. Petitioners' argument that the actual taking would take effect only upon payment of just compensation is contrary to the established principle that the valuation should be based on the time of taking.
Main Doctrine
A landowner who executes a Deed of Assignment of Rights, acknowledging receipt of full compensation for their property and assigning their rights to the Land Bank of the Philippines, is estopped from claiming an increase in the valuation of such property, especially when such claim is raised after an unreasonable and unexplained delay, constituting laches.