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JurisprudenceG.R. No. 175055 -

G.R. No. 175055 - LAND BANK OF THE PHILIPPINES, VS. HEIRS OF MAXIMO PUYAT AND GLORIA PUYAT, REPRESENTED BY ATTORNEY-IN-FACT MARISSA PUYAT.D E C I S I O N - Supreme Court E-Library

Cited Laws

RA 108,RA 207,RA 970RA 727,RA 6657,RA 415,RA 6657RA 9700RA 117,RA 181,RA 291,RA 226,RA 9700,RA 90,RA 627,
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TL;DR — Ruling

WHEREFORE , the decision dated May 11, 2004 as amended by the order dated September 3, 2004 is AFFIRMED subject to the modification that the reckoning of the 6% interest per annum shall be from March 21, 1990. Costs of suit shall be paid by the petitioner. SO ORDERED . [4] Factual Antecedents Gloria and Maximo Puyat, [5] both deceased, are the registered owners of a parcel of riceland consisting of 46.

Decision

Ruling

WHEREFORE , the decision dated May 11, 2004 as amended by the order dated September 3, 2004 is AFFIRMED subject to the modification that the reckoning of the 6% interest per annum shall be from March 21, 1990. Costs of suit shall be paid by the petitioner. SO ORDERED . [4] Factual Antecedents Gloria and Maximo Puyat, [5] both deceased, are the registered owners of a parcel of riceland consisting of 46.8731 hectares located in Barangay Bakod Bayan, Cabanatuan City, Province of Nueva Ecija (subject property). Respondents are the heirs of Gloria and Maximo Puyat, and the pro-indiviso co-owners of the subject property. The records do not disclose when the Department of Agrarian Reform (DAR) placed 44.3090 hectares of Puyats land under Operation Land Transfer pursuant to PD 27. It is, however, clear that the DAR issued several emancipation patents in favor of various farmer-beneficiaries in December 1989. [6] All of the said patents were annotated on Puyats Transfer Certificate of Title (TCT) No. 1773 on March 20, 1990, and thereby caused the concomitant partial cancellation of Puyats title. The Puyats did not receive any compensation for the cancellation of their title over the awarded portions of the subject property. It was only on September 18, 1992 (more than two years after the DAR awarded the property to farmer-beneficiaries) that the Land Bank of the Philippines (Land Bank) received DARs instruction to pay just compensation to the Puyats. [7] Accordingly, Land Bank made its initial valuation of P2,012.50 per hectare or a total of P92,752.10. Deducting the farmers lease rentals amounting to P5,241.20, the Land Bank recommended the payment to the landowners of the net value of P87,510.90. [8] Respondents received Land Banks initial valuation together with the Notice of Acquisition and Valuation Form, and rejected the valuation for being ridiculously low. The heirs of Puyat filed a complaint for determination and payment of just compensation [9] with the Regional Trial Court (RTC) of Cabanatuan City, Nueva Ecija on November 24, 1998. The complaint, docketed as Agr. Case No. 124-AF, was raffled to Branch 23 of the said court. Respondents presented the supervising agriculturalist from the City Agro-Industrial Office, who testified that the average palay production for Barangay Bakod Bayan ranges from 70 to 80 cavans per hectare. [10] Another officer from the same office testified that the average annual palay production is around 65 cavans per hectare. [11] The zoning officer of the City Planning and Development Office testified that the subject property is located in the agro-industrial district, which is near the central business district of Cabanatuan City. [12] The zonal value determined by the Bureau of Internal Revenue (BIR) for this area is P10.00 per square meter. [13] Respondents prayed that their 468,731 square meter-property be valued at P100,000.00 per hectare. [14] The Land Bank and the DAR answered that the valuation was made