Landbank vs Cruz GR 175175, Sep. 29, 2008 567 SCRA 31

Fact: The respondent voluntarily offered to sell the parcel of land to the DAR under the CARL of 1988. After conducting a field investigation, The LBP valued the property at ₱298,101.21, after the value of the 0.3643 hectare legal easement on the property was deducted. The respondents rejected the LBP’s offer and elevated the matter to PARAD who conducted a summary administrative proceeding for the determination of just compensation who fixed the just compensation for the respondents’ at ₱928,330.17, which was ₱630,228.96 more than the amount offered by the LBP. The huge difference from the LBP’s estimate arose from the PARAD’s use of the average selling price of ₱16.00 per kg. of copra instead of the average selling price of ₱5.86 per kg. of copra used by the LBP. The average selling price data is required in computing for the capitalized net income (CNI),10 which is a necessary factor in the equation for determining the amount of just compensation. The LBP moved to reconsider the PARAD’s ruling, was denied. Hence, the LBP filed before the RTC-SAC of Sorsogon City a petition for the judicial determination of just compensation who affirmed the PARAD’s decision and denied the subsequent motion for reconsideration. The LBP appealed to the CA who affirmed the RTC-SAC’s ruling. The LBP moved to reconsider the CA’s decision, but its motion was denied. Hence this Petition.

Issue: Whether the determination of just compensation be reviewed by the SC with the absences of the of proof to show that the RTC-SAC acted arbitrarily in the appreciation and weighing of the evidence

Held: No, In the absence of proof to show that the RTC-SAC acted arbitrarily in the appreciation and weighing of the evidence, we respect the RTC-SAC’s findings. Factual findings and determinations made by the RTC, or in this case the RTC-SAC, are generally binding on the Court, particularly when affirmed by the CA. The court find the present issue to be a question of fact that is not reviewable by this Court. To differentiate, a question of fact exists when the doubt centers on the truth or falsity of the alleged facts while a question of law exists if the doubt centers on what the law is on a certain set of facts; there is a question of fact if the issue requires a review of the evidence presented or requires the re-evaluation of the credibility of witnesses, and there is a question of law if the issue raised is capable of being resolved without the need of reviewing the probative value of the evidence. The issue of the correctness of the average selling price data used in this case is clearly a question of fact that can only be determined by a review of the evidence presented by the parties.

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