Land Bank v. Costo
REITERATIONFacts
The Antecedents: Respondents Spouses Rosa and Pedro Costo are the registered owners of a 9.1936-hectare land. Out of this, 7.3471 hectares were deemed qualified for acquisition under the Comprehensive Agrarian Reform Program (CARP). The Land Bank of the Philippines (Land Bank) valued this portion at P104,077.01, which the respondents rejected. The Land Bank deposited this amount as provisional compensation. The Provincial Agrarian Reform Adjudicator (PARAD) recomputed the valuation to P468,575.92, which was affirmed by the Regional Trial Court (RTC) acting as a Special Agrarian Court (SAC). Procedural History: The PARAD ruled in favor of the respondents, fixing the land valuation at P468,575.92. The Land Bank's motion for reconsideration was denied. The Land Bank then filed a petition with the SAC, which affirmed the PARAD's decision. The Court of Appeals (CA) also affirmed the SAC's decision. The Petition: The Land Bank filed a petition for review on certiorari before the Supreme Court, arguing that the CA gravely erred in affirming the SAC's decision, as the compensation fixed was not in accordance with the valuation factors under Section 17 of R.A. No. 6657 and DAR Administrative Order No. 5, Series of 1998.
Issue(s)
Whether the Special Agrarian Court (SAC) and the Court of Appeals (CA) erred in affirming the PARAD's valuation of the subject property as just compensation, allegedly in violation of Section 17 of R.A. No. 6657 and DAR Administrative Order No. 5, Series of 1998. Whether the valuation made by the Land Bank of the Philippines (Land Bank) should have been given more weight, considering the role of administrative agencies and the scope of Supreme Court review.
Ruling
The petition is denied. The Decision dated July 14, 2006, and the Resolution dated September 15, 2006, of the Court of Appeals in CA-G.R. SP No. 91469 are affirmed.
Ratio Decidendi
On the issue of just compensation valuation and the application of Section 17 of R.A. No. 6657 and DAR AO No. 5, Series of 1998: The Supreme Court affirmed the decisions of the CA, SAC, and PARAD. The Court reiterated that the determination of just compensation is a judicial function, and the initial valuation by the Land Bank or DAR is not conclusive. The SAC, in affirming the PARAD's decision, considered all the relevant evidence presented by the parties, including the factors enumerated in Section 17 of R.A. No. 6657, which have been translated into a basic formula by DAR AO No. 5, Series of 1998. The Court found that the SAC did not abuse its discretion and that its valuation was a more realistic appraisal of the property's worth compared to the Land Bank's assessment, which was deemed unrealistically low. The Court emphasized that the nature, actual use, and income of the property are only among the factors to be considered. The petitioner's contention that the PARAD violated the AO was dismissed, as the nature, actual use, and income of the property is only one of the factors considered. The Court distinguished the present case from Land Bank of the Philippines v. Banal. The SAC upheld the PARAD's determination after considering the relevant evidence of all parties. On the weight of the Land Bank's valuation, the role of administrative agencies, and the scope of Supreme Court review: The Court reiterated that factual findings of administrative agencies with expertise, such as the PARAD, are generally accorded respect. Any valuation by the Land Bank should only be regarded as an initial valuation, not conclusive or controlling, to prevent the Land Bank or DAR from usurping the judicial function of determining just compensation. The SAC's decision was based on factual grounds after considering the evidence, and the Land Bank failed to convince the Court that the SAC abused its discretion. The matters raised by the petitioner primarily involved factual controversies, which are beyond the ambit of the Supreme Court's review. The Supreme Court is not a trier of facts and is not the proper forum for the ventilation and substantiation of factual issues.
Main Doctrine
The determination of just compensation for lands acquired under the Comprehensive Agrarian Reform Program (CARP) is a judicial function, and the valuation made by the Land Bank of the Philippines (Land Bank) or the Department of Agrarian Reform (DAR) serves only as an initial valuation, not conclusive or binding upon the courts. Special Agrarian Courts (SACs) must consider all the factors enumerated in Section 17 of R.A. No. 6657, including the formula provided in DAR Administrative Order No. 5, Series of 1998, in fixing the just compensation.