Cited Laws
TL;DR — Ruling
We find and so hold that the Petitioner failed to sufficiently show that the RTC ignored, misconstrued, or misapplied any cogent facts and circumstances which, if considered, would warrant a modification or reversal of the outcome of the case.
Accordingly , the determined amount by the Court [ a quo ], in eminent domain terms, is the " real, substantial, full and ample " compensation the government must pay to be " just " to the landowner, herein petitioner . [13] (citations omitted) Unsatisfied with the decision, Prado and Land Bank filed their respective motions for reconsideration. However, both motions were denied. Thus, they sought relief before the Court. CA-G.R. SP No. 125471 Land Bank contended that the RTC's valuation of the subject land did not consider the pertinent guidelines issued by the Department of Agrarian Reform (DAR) but instead created its own version of the applicable guidelines, which is not allowed under settled jurisprudence. [14] The CA First Division, however, was not convinced, ruling in this wise: As the law now stands, it is clear that the RTC, acting as Special Agrarian Court, is duty-bound to take into consideration the factors fixed by Section 17 of Republic Act (RA) No. 6657, as amended, and apply the basic formula prescribed and laid down in the pertinent administrative regulations. After a judicious evaluation of the petition, as well as the evidence on record, We find and so hold that the Petitioner failed to sufficiently show that the RTC ignored, misconstrued, or misapplied any cogent facts and circumstances which, if considered, would warrant a modification or reversal of the outcome of the case. On the contrary, it conformed with the factors listed in Section 17 of the above law in determining just compensation. In the absence of proof to show that it committed grievous error in its dispositions, We have to respect its findings. [15] Undaunted, Land Bank proceeded before the Court via a petition for review questioning the above disposition. Collectively, the issues for resolution are as follows: I. WHETHER OR NOT THE COURT OF APPEALS ERRED IN AFFIRMING THE SAC'S DETERMINATION OF JUST COMPENSATION. II. WHETHER OR NOT THE COURT OF APPEALS ERRED IN AFFIRMING THE JUDGMENT OF THE SAC ORDERING THE IMMEDIATE PAYMENT OF ITS ADJUDGED JUST COMPENSATION, WITH INTEREST AT 12% IF UNHEEDED WITHIN 30 DAYS FROM NOTICE, EVEN IF THE ORDER IS NOT YET FINAL AND EXECUTORY. Court's Ruling The Court finds the petition filed by Land Bank partly meritorious. In eminent domain, the determination of just compensation is principally a judicial function of the Regional Trial Court, acting as a Special Agrarian Court. [16] It exercises original and exclusive jurisdiction over all petitions for the determination of just compensation to landowners. [17] The RTC-SAC, however, must comply with the Court's ruling in Alfonso v. Land Bank of the Philippines [18] necessitating compliance with the guidelines and factors laid down by law in determining just compensation, where the Court specifically emphasized that: For the guidance of the bench, the bar, and the public, we reiterate the rule: Out of regard for the DAR's expertise as the concerned implementing agency, courts should he
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