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Land Bank of the Philippines vs. Eugenio Dalauta
G.R. No. 190004 August 8, 2017
PONENTE: JusticeJose Catral Mendoza
Eugenio Dalauta (Dalauta) was the registered owner of an agricultural land in Florida, Butuan City. The land was placed by the Department of Agrarian Reform (DAR) under compulsory acquisition of the Comprehensive Agrarian Reform Program (CARP). Thus, Dalauta received on February 7, 1994 a Notice of Coverage notifying him that his land was subject of expropriation. Land Bank of the Philippines (LBP) offered ₱192,782.59 as compensation for the land, but Dalauta rejected such valuation for being too low.
The case was referred to the DAR Adjudication Board (DARAB). A summary administrative proceeding was conducted to determine the appropriate just compensation for the subject property. In its Resolution, the PARAD affirmed the valuation made by LBP in the amount of ₱192,782.59.
Dalauta filed a petition for determination of just compensation with the RTC, sitting as Special Agrarian Court (SAC).
Dalauta argued that the valuation of his land should be determined using the formula in DAR A.O. No. 6, series of 1992, which was Land Value (LV) = Capitalized Net Income (CNI) x 0.9 + Market Value (MV) per tax declaration x 0.1, as he had a net income of ₱350,000.00 in 1993 from the sale of the trees that were grown on the said land to Norberto C. Fonacier.
On May 30, 2006, the SAC rendered its decision pegging the just compensation in the amount of ₱2,639,557.00, higher than the value made by LBP. Unsatisfied, LBP filed a motion for reconsideration, but it was denied by the SAC.
Hence, LBP filed a petition for review under Rule 42 of the Rules of Court before the CA, arguing, among others that the SAC erred in taking cognizance of the case when the DARAB decision sustaining the LBP valuation had long attained finality and that the SAC violated Republic Act (R.A.) No. 6657 and DAR A.O. No. 6, series of 1992, in fixing the just compensation.
The CA ruled that the SAC correctly took cognizance of the case. It ruled that the SAC had original and exclusive jurisdiction over all petitions for the determination of just compensation.
Yes. It is clear from Sec. 57 that the RTC, sitting as a Special Agrarian Court, has "original and exclusive jurisdiction over all petitions for the determination of just compensation to landowners." This "original and exclusive" jurisdiction of the RTC would be undermined if the DAR would vest in administrative officials original jurisdiction in compensation cases and make the RTC an appellate court for the review of administrative decisions. Thus, although the new rules speak of directly appealing the decision of adjudicators to the RTCs sitting as Special Agrarian Courts, it is clear from Sec. 57 that the original and exclusive jurisdiction to determine such cases is in the RTCs. Any effort to transfer such jurisdiction to the adjudicators and to convert the original jurisdiction of the RTCs into appellate jurisdiction would be contrary to Sec. 57 and therefore would be void.
Thus, direct resort to the SAC by private respondent is valid.
No. On Just Compensation
Upon an assiduous assessment of the different valuations arrived at by the DAR, the SAC and the CA, the Court agrees with the position of Justice Francis Jardeleza that just compensation for respondent Dalauta's land should be computed based on the formula provided under DAR-LBP Joint Memorandum Circular No. 11, series of 2003 (JMC No. 11 (2003). The case was remanded to the Regional Trial Court, Branch 5, Butuan City, sitting as Special Agrarian Court, for purposes of computing just compensation in accordance with JMC No.11.