Land Bank v. Heirs of Listana
REITERATIONFacts
The Antecedents: Severino Listana voluntarily sold a 246.0561-hectare property to the government under Republic Act (RA) No. 6657. The Department of Agrarian Reform Adjudication Board (DARAB) set the just compensation at P10,956,963.25. The Provincial Agrarian Reform Adjudicator (PARAD) issued a writ of execution ordering Land Bank of the Philippines (LBP) to pay Listana, but LBP refused. Listana filed a motion for contempt against the LBP Manager, Alex A. Lorayes. Procedural History: LBP filed a petition for judicial determination of just compensation with the Regional Trial Court (RTC), acting as a Special Agrarian Court (SAC), praying for a lower amount. The PARAD cited Lorayes for indirect contempt and ordered his imprisonment. The SAC dismissed LBP's petition for judicial determination. The PARAD issued an alias writ of execution and a warrant of arrest against Lorayes. LBP filed a petition for injunction with the RTC to enjoin the PARAD from implementing the warrant of arrest, posting a P5,644,773.02 cash bond. The RTC granted the injunction. Listana's motion for reconsideration was denied. The Court of Appeals (CA) set aside the RTC's orders. In Land Bank of the Philippines v. Listana, Sr. (G.R. No. 152611), the Supreme Court reversed the CA, reinstated the RTC's orders, and declared void all proceedings stemming from Listana's motion for contempt, citing procedural infirmities in the contempt charge. The Petition: After the Supreme Court's decision in G.R. No. 152611 became final, LBP filed a motion to withdraw the P5,644,773.02 cash bond. The RTC denied the motion, holding that the bond was posted to secure any damages Listana might incur due to the injunction and that its purpose was not mooted by the Supreme Court's decision, as the main issue of just compensation was still pending. The CA affirmed the RTC's denial, stating that the Supreme Court's decision only nullified the PARAD's contempt orders and reinstated the preliminary injunction, which requires a bond. LBP filed the present petition for review on certiorari.
Issue(s)
Whether the Court of Appeals erred in not allowing the withdrawal of the P5,644,773.02 cash bond pending the final determination of just compensation. Whether the cash bond posted for the preliminary injunction became moot and academic upon the finality of the Supreme Court's decision in G.R. No. 152611, considering the pending issue of just compensation.
Ruling
The petition is unmeritorious. The Court denies the petition and affirms the Decision and Resolution of the Court of Appeals.
Ratio Decidendi
On the issue of withdrawing the cash bond: The Court held that LBP cannot withdraw the P5,644,773.02 cash bond pending the final determination of the amount of just compensation for the property. The dispositive portion of the RTC's 29 January 2001 Order, which was reinstated by the Supreme Court in Land Bank of the Philippines v. Listana, Sr., clearly states that the PARAD is enjoined from enforcing the order of arrest against Mr. Alex A. Lorayes pending the final termination of the case before RTC Branch 52, Sorsogon upon the posting of a cash bond by Land Bank. This explicitly links the injunction to the pendency of the just compensation case. The purpose of an injunction bond, as stated in Section 4(b), Rule 58 of the Rules of Court, is to answer for damages the enjoined party may sustain if the applicant is ultimately found not entitled to the injunction. In this case, the bond is intended to secure any damages Listana may suffer if the courts eventually uphold the DARAB's valuation of P10,956,963.25, especially since the SAC has original and exclusive jurisdiction over just compensation cases and the DARAB's valuation is merely preliminary if challenged. The Supreme Court's decision in G.R. No. 152611, while nullifying the contempt proceedings, specifically reinstated the preliminary injunction, which necessitates the continued existence of the bond. On whether the cash bond became moot and academic: The Court found that the bond did not become moot and academic. The Supreme Court's decision in Land Bank of the Philippines v. Listana, Sr., while declaring the contempt proceedings void due to procedural infirmities and lack of jurisdiction by the PARAD, did not resolve the main issue of just compensation. Instead, it reinstated the RTC's order for a preliminary injunction, which was conditioned upon the posting of the cash bond. The underlying reason for the injunction was the pendency of LBP's petition for judicial determination of just compensation before the SAC. As long as this issue remains unsettled, the injunction against the execution of the DARAB's decision remains in effect, and the bond serves its purpose of protecting Listana from potential damages. The RTC correctly reasoned that the bond was posted to secure damages Listana might incur by reason of the injunction, specifically the delay in receiving just compensation for his expropriated property. The Supreme Court's ruling did not expressly or impliedly order the release of the bond; it merely upheld the injunction pending the final resolution of the just compensation case. Therefore, the bond remains valid until the final termination of the main action before the SAC.
Main Doctrine
A cash bond posted for a writ of preliminary injunction enjoining the execution of a DARAB decision on just compensation remains valid and cannot be withdrawn until the final determination of the just compensation case before the Special Agrarian Court, as the bond is intended to answer for damages the landowner may sustain if the injunction is ultimately found to be unjustified.