Land Bank v. Briones-Blanco
REITERATIONFacts
The Antecedents: Respondents, co-owners of an agricultural land (subject land) covered by TCT No. T-2583, filed a petition for judicial determination of just compensation after the Department of Agrarian Reform (DAR) compulsorily placed the land under the coverage of Republic Act (RA) No. 6657 (Comprehensive Agrarian Reform Law). The DAR and Land Bank of the Philippines (petitioner) valued the land at ₱18,284.28 per hectare for the coco land portion and ₱8,738.50 per hectare for the rice land portion. Procedural History: The Regional Trial Court (RTC), sitting as a Special Agrarian Court (SAC), constituted a Board of Commissioners. The commissioners submitted differing valuations. The RTC, in its Decision dated September 18, 2009, fixed the just compensation at ₱4.00 per square meter or ₱40,000.00 per hectare, finding a median on figures from various appraisers and brokers. The RTC denied petitioner's motion for reconsideration. The Court of Appeals (CA), in its Decision dated November 19, 2013, affirmed the RTC's ruling, holding that strict adherence to DAR AO No. 5 is not required and that relevant evidence and reasonable factors may be used. The CA denied petitioner's motion for reconsideration. The Petition: Petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's Decision and Resolution, primarily questioning the RTC's disregard of DAR AO No. 5 guidelines in determining just compensation.
Issue(s)
Whether the disregard of DAR AO No. 5 as guidelines for determining just compensation is proper in this case.
Ruling
The Court partially granted the petition, reversed and set aside the CA's Decision and Resolution, and remanded the case to the court of origin for proper determination of just compensation. WHEREFORE, premises considered, the instant petition is PARTIALLY GRANTED. The Decision dated November 19, 2013 and the Resolution dated June 20, 2014 of the Court of Appeals in CA-G.R. SP No. 03346-MIN are REVERSED and SET ASIDE. Accordingly, the case is REMANDED to the court of origin for proper determination of just compensation. SO ORDERED.
Ratio Decidendi
On the issue of disregarding DAR AO No. 5: The Court held that while courts are not strictly confined to the formula provided by DAR AO No. 5 for determining just compensation, any deviation must be clearly explained and justified by the circumstances of the case. The RTC failed to provide a reasoned explanation for its deviation from the guidelines, merely stating that it found ₱4.00 per square meter to be just, reasonable, and fair. The RTC based its valuation on various estimates but did not adequately explain why it opted to deviate from the established rules or the specific factors that warranted such deviation. Jurisprudence emphasizes the duty of the RTC, acting as Special Agrarian Courts, to explain the reasons for departing from the DAR formula, as such guidelines are enacted to comply with the objectives of agrarian reform and carry the presumption of legality. The RTC's complete disregard of the DAR formula and Section 17 of RA 6657 without stating their inapplicability was deemed improper. Furthermore, both parties failed to present satisfactory evidence of the property's value at the time of taking, and the Supreme Court, not being a trier of facts, could not receive new evidence. Therefore, a remand to the court of origin for a proper determination of just compensation was deemed necessary.
Main Doctrine
While courts are not strictly confined to the DAR formula for determining just compensation, any deviation must be clearly explained and justified by the circumstances of the case, supported by evidence, and must not disregard the objectives of agrarian reform.