Land Bank of the Philippines v. Jocson and Sons
REITERATIONFacts
The Antecedents: The case involves a 27.3808-hectare portion of tenanted rice land covered by Transfer Certificates of Title (TCT) Nos. T-72323 and T-72324, registered in the name of J. L. Jocson and Sons (respondent). The property was placed under the coverage of the government's Operation Land Transfer (OLT) pursuant to Presidential Decree (P.D.) No. 27 and awarded to tenant-beneficiaries. The Department of Agrarian Reform (DAR) initially valued the compensation at ₱250,563.80. This valuation was later increased to ₱903,637.03 after computing the 6% annual interest increment. Respondent withdrew this amount in 1997, without prejudice to the outcome of its case to fix just compensation. Procedural History: Finding the DAR's offer grossly inadequate, respondent filed a complaint on July 18, 1997, before the Regional Trial Court of Bacolod City, Branch 46, sitting as a Special Agrarian Court (SAC), against Land Bank of the Philippines (petitioner), the DAR, and the tenant-beneficiaries, for the determination and fixing of just compensation. The SAC, after considering the report of appointed Commissioners, fixed the just compensation at ₱2,564,403.58. The SAC adopted a higher valuation (₱93,657.00/hectare) that the DAR had applied to a similar adjacent landholding. The SAC disposed by ordering Land Bank to pay respondent ₱1,660,766.55. Both petitioner and DAR moved for reconsideration, which were denied. Petitioner appealed to the Court of Appeals (CA) via petition for review. Petitioner argued that the SAC erred in using ₱300.00 as the Government Support Price (GSP) in 1992 instead of ₱35.00 as provided under E.O. No. 228. The Petition: The CA dismissed petitioner's petition for review for lack of jurisdiction, holding that the issue of whether P.D. No. 27 and E.O. No. 228 or R.A. No. 6657 should govern the valuation involved pure questions of law, cognizable only by the Supreme Court. After its motion for reconsideration was denied, petitioner filed the present petition for review, arguing that the issues raised before the CA were mixed questions of fact and law, hence cognizable by the CA. The Supreme Court agreed to resolve the lone substantive issue: whether the SAC erred in using ₱300.00 as the GSP in 1992.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for review for lack of jurisdiction. Whether the Special Agrarian Court erred in using ₱300.00 as the Government Support Price (GSP) in 1992 in determining just compensation for the property acquired under Presidential Decree No. 27 and Executive Order No. 228.
Ruling
The Supreme Court ruled that the Court of Appeals erred in dismissing the petition for review for lack of jurisdiction. The Court reinstated the May 19, 2003 Decision of the Special Agrarian Court, finding that Republic Act No. 6657 is the applicable law for determining just compensation in cases where payment has not been completed, even if the land was acquired under Presidential Decree No. 27 and Executive Order No. 228. The SAC's determination of just compensation was found to be in accordance with RA 6657 and existing jurisprudence.
Ratio Decidendi
On the jurisdiction of the Court of Appeals: The Court held that a petition for review under Rule 42 of the Revised Rules of Court is the appropriate mode of appeal from decisions of RTCs acting as SACs. Jurisdiction over such appeals resides in the Court of Appeals, and such petitions may raise questions of fact, law, or mixed questions of fact and law. Therefore, the CA erred in dismissing the petition for review solely on the ground of jurisdiction. On the applicable law for just compensation: The Court reiterated its ruling in Land Bank of the Philippines v. Chico and other cases, stating that Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988) is the relevant law for determining just compensation, even for properties acquired under P.D. No. 27 and E.O. No. 228, provided that the payment of just compensation had not been completed prior to the enactment of RA 6657. The Court clarified that the "taking" of the landholding for purposes of agrarian reform occurs upon the payment of just compensation, not on the effectivity date of P.D. No. 27. Since the agrarian reform process, specifically the settlement of just compensation, was incomplete when RA 6657 was passed, the provisions of RA 6657 control. P.D. No. 27 and E.O. No. 228 have only suppletory effect in such cases. The Court emphasized that just compensation must be the full and fair equivalent of the property taken, which is best achieved by applying the more equitable provisions of RA 6657. The SAC's adoption of ₱300.00 as the GSP for 1992 was deemed in order as petitioner failed to present contrary evidence. The SAC's determination of just compensation at ₱93,657.00 per hectare was found to be proper, considering factors like the nature of the land, its productivity, market value, and the higher valuation applied by DAR to an adjacent property acquired under RA 6657.
Main Doctrine
Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988) governs the determination of just compensation for lands acquired under Presidential Decree No. 27 and Executive Order No. 228, even if the acquisition process began prior to the enactment of RA 6657, provided that full payment of just compensation has not yet been completed.