Land Bank v. Lopez
REITERATIONFacts
The Antecedents: The respondent heirs owned a parcel of coconut land. They voluntarily offered to sell it to the Department of Agrarian Reform (DAR) under Republic Act (R.A.) No. 6657. The Land Bank of the Philippines (LBP) valued the property at ₱304,735.09, later reduced to ₱298,101.21 after deducting the value of a legal easement. Procedural History: The respondents rejected the LBP's offer and elevated the matter to the DAR Provincial Agrarian Reform Adjudicator (PARAD). The PARAD fixed the just compensation at ₱928,330.17, using an average selling price of ₱16.00 per kg. of copra, significantly higher than the LBP's valuation which used ₱5.86 per kg. The LBP's motion for reconsideration was denied. The LBP then filed a petition before the Regional Trial Court, acting as a Special Agrarian Court (RTC-SAC), for judicial determination of just compensation, arguing that the PARAD gravely abused its discretion by using a selling price contrary to DAR regulations. The RTC-SAC affirmed the PARAD's decision, finding the valuation fair, just, and realistic, considering various factors beyond just the copra price. The RTC-SAC denied the LBP's motion for reconsideration. The LBP appealed to the Court of Appeals (CA). The CA affirmed the RTC-SAC's ruling, finding the LBP's claims unsubstantiated and its valuation unrealistic. The CA denied the LBP's motion for reconsideration. The Petition: The LBP filed a petition for review on certiorari with the Supreme Court, insisting that the Philippine Coconut Authority (PCA)-supplied average selling price data of ₱5.86 per kg. of copra should have been used, as it complied with DAR A.O. No. 5, series of 1998.
Issue(s)
Whether the Supreme Court can review the correctness of the average selling price data used in determining just compensation, which is a question of fact. Whether the Court of Appeals erred in affirming the valuation of the property by the RTC-SAC and PARAD.
Ruling
The Supreme Court denied the petition for review on certiorari, affirming the decision of the Court of Appeals. The Court held that the issue of the correctness of the average selling price data used in determining just compensation is a question of fact, which is not reviewable under Rule 45 of the Rules of Court. The Court found no proof that the RTC-SAC acted arbitrarily in appreciating the evidence and therefore respected its findings, which were affirmed by the CA.
Ratio Decidendi
On the issue of reviewing questions of fact: The Supreme Court reiterated that a petition for review on certiorari under Rule 45 of the Rules of Court is limited to questions of law and does not ordinarily entertain questions of fact. A question of fact arises when the doubt centers on the truth or falsity of alleged facts, requiring a review of the evidence presented or re-evaluation of witness credibility. Conversely, a question of law is resolvable without reviewing the probative value of the evidence. In this case, the correctness of the average selling price data used in determining just compensation is a question of fact, as it necessitates a review of the evidence presented by the parties to ascertain its truth or falsity. Therefore, the Supreme Court cannot delve into this matter under the present petition. On the issue of affirming the valuation: The Supreme Court emphasized that factual findings and determinations made by the RTC, particularly when affirmed by the CA, are generally binding on the Supreme Court. In the absence of any proof demonstrating that the RTC-SAC acted arbitrarily in its appreciation and weighing of the evidence, the Court respects these findings. The CA found the LBP's claims unsubstantiated and its valuation unrealistic, and affirmed the RTC-SAC's valuation as fair, just, and realistic, considering the factors enumerated in Section 17 of R.A. No. 6657 and the guidelines in DAR A.O. No. 5, series of 1998. The CA correctly observed that both the LBP and the PARAD used the same formula but differed on the average selling price data, and that the RTC-SAC's valuation was not shown to have disregarded the relevant factors and guidelines.
Main Doctrine
The Supreme Court will not review questions of fact in a petition for review on certiorari under Rule 45, as such petitions are limited to questions of law. Factual findings of the Regional Trial Court, acting as a Special Agrarian Court, when affirmed by the Court of Appeals, are binding on the Supreme Court, absent any showing of arbitrariness.