Landbank vs Celada GR 164876, Jan. 23, 2006

Fact: Respondent owner agricultural land was identified by the DAR as suitable for compulsory acquisition under the CARP. The matter was then indorsed to petitioner LBP for field investigation and land valuation. In due course, LBP valued respondent’s land at P299,569.61. The DAR offered the same amount to respondent as just compensation, but it was rejected. Nonetheless, LBP deposited the said sum in cash and bonds in the name of respondent. Pursuant to the CARL, the matter was referred to the DARAB for summary administrative hearing on determination of just compensation. While the DARAB case was pending, respondent filed, a petition for judicial determination of just compensation against LBP, the DAR and the MARO before the RTC which was the designated SAC. Respondent alleged that the current market value of her land is at least P150,000.00 per hectare based a number of factors. LBP filed its Answer7 raising non-exhaustion of administrative remedies as well as forum-shopping as affirmative defense. According to petitioner, respondent must first await the outcome of the DARAB case before taking any judicial recourse; that its valuation was arrived at by applying the formula prescribed by law whereas respondent’s was based only on the “current value of like properties”. the SAC fixes the compensation of the land of petitioner at P354,847.50 and which shall earn legal interest of twelve percent (12%) per annum from the time of its taking by the DAR and to indemnify petitioner for attorney’s fee and incidental expenses. LBP elevated the matter to the Court of Appeals which, however, dismissed the appeal outright. Upon denial of its motion for reconsideration, LBP filed the instant petition under Rule 45 of the Rules of Court, hence this petition.

Issue: Whether the SAC erred in setting aside petitioner’s valuation of respondent’s land on the sole basis of the higher valuation given for neighboring properties.

Held: Yes, the SAC cannot ignore administrative issuances in the determination of the Just Compensation of the expropriated land especially when, as in this case, its validity was not put in issue. The petitioner arrived at its valuation by using available factors culled from the Department of Agriculture and Philippine Coconut Authority, and by computing the same in accordance with the formula provided in the said administrative order. Under the circumstances, the court find the explanation and computation of petitioner to be sufficient and in accordance with applicable laws. Petitioner’s valuation must thus be upheld.

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