Land Bank v. Dumlao
REITERATIONFacts
The Antecedents: This case involves a Motion for Reconsideration filed by petitioner Land Bank of the Philippines (LANDBANK) from the Supreme Court's Decision dated November 27, 2008, which affirmed the Court of Appeals' Decision. The core issue revolves around the determination of just compensation for lands covered by Presidential Decree (PD) No. 27. Procedural History: The Court of Appeals had previously affirmed a decision regarding the determination of just compensation. LANDBANK sought reconsideration of the Supreme Court's affirmation of the CA decision. The Petition: Petitioner LANDBANK insisted on the application of the formula prescribed in PD No. 27 and Executive Order (EO) No. 228 for computing the Land Value (LV) of properties covered by PD No. 27, citing the case of Gabatin v. Land Bank of the Philippines. LANDBANK also argued that the Court ruled Republic Act (RA) No. 6657 retroactively applied to lands acquired under PD No. 27.
Issue(s)
Whether the pronouncement in Gabatin v. Land Bank of the Philippines should guide the Court in settling the issue as to what constitutes just compensation for the lands covered by Presidential Decree (PD) No. 27. Whether Republic Act (RA) No. 6657 is the principal law governing the determination of just compensation for lands acquired pursuant to PD No. 27, and whether it can be applied retroactively.
Ruling
The Supreme Court denied the Motion for Reconsideration filed by petitioner Land Bank of the Philippines. The case was remanded to the trial court for the final determination of just compensation due to the respondents.
Ratio Decidendi
On the applicability of Gabatin v. Land Bank of the Philippines: The Court held that the petitioner's reliance on Gabatin was misplaced. The Gabatin case involved issues not present in the current controversy, specifically concerning the applicable Government Support Price (GSP) for palay and whether it should be pegged at the time of taking. Furthermore, the petitioners in Gabatin did not question the formula prescribed in PD No. 27 and EO No. 228, unlike the respondents in the present case. Therefore, the ruling in Gabatin could not be applied to the facts at bar. On the determination of just compensation and the application of RA No. 6657: The Court reiterated that the determination of just compensation in eminent domain cases is a judicial prerogative. It cited Export Processing Zone Authority v. Dulay to emphasize that no statute, decree, or executive order can override the court's findings on the 'just-ness' of the decreed compensation. The Court clarified that its pronouncement regarding RA No. 6657 was not an undue stretching of its previous ruling. It explained that Section 17 of RA No. 6657 applies only if the just compensation for lands acquired under PD No. 27 remains unresolved after the passage of RA No. 6657. In such instances, the computation should be in accordance with RA No. 6657, giving it retrospective application only to the extent necessary to resolve the unsettled compensation.
Main Doctrine
The determination of just compensation in eminent domain cases is a judicial function, and no statute, decree, or executive order can mandate that its own determination shall prevail over the court's findings. If just compensation was not settled prior to the passage of Republic Act No. 6657, it should be computed in accordance with said law, even if the property was acquired under Presidential Decree No. 27.