CASE DIGEST

Written By: Celine Carpio

Case Name: LBP v. Celada (2006)
Doctrine:
1) It is clear from Sec. 57 (of CARP) that RTC, sitting as SAC, has original and exclusive
jurisdiction over all petitions for the determination of just compensation to landowners
2) While SAC is required to consider the acquisition cost of the land, the current value of like
properties, its nature, actual use and income, the sworn valuation by the owner, the tax
declaration and the assessments made by the government assessors to determine just
compensation, it is equally true that these factors have been translated into a basic formula by
the DAR pursuant to its rule-making power under Section 49 of R.A. No. 6657. As the
government agency principally tasked to implement the agrarian reform program, it is the DAR's
duty to issue rules and regulations to carry out the object of the law. DAR A.O. No. 5, s. of
1998 precisely "filled in the details" of Section 17, R.A. No. 6657 by providing a basic
formula by which the factors mentioned therein may be taken into account.
The SAC was at no liberty to disregard the formula which was devised to implement the
said provision. It is elementary that rules and regulations issued by administrative bodies to
interpret the law which they are entrusted to enforce, have the force of law, and are entitled
to great respect.
Facts:
Leonila Celada owns 22.3167 hectares of agricultural land at Bohol. The land was identified by
Department of Agrarian Reform (DAR) as suitable for compulsory acquisition under CARP.
LBP valued respondents land at P2.1105517 per square meter. Total aggregate value of
P299,569.61. Respondent rejected the said offer for just compensation.
Pursuant to R.A. 6657 / CARP Law, the matter was referred to DAR Adjudication Board
(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, DAR at RTC. The case was raffled to the Branch 3, Special Agrarian
Court (SAC).
SAC rendered judgment as follows:
P2.50 per square meter
Total value of P354,847.50 for 14.1939 hectares
Issue:
1) WON Special Agrarian Court has jurisdiction for the determination of just compensation while
Administrative proceeding is ongoing before the DARAB
2) WON Special Agrarian Court erred in fixing the just compensation of the land based not on its
actual land use but on the value of neighboring lands
Ruling:
1) No. SAC properly took cognizance of respondents petition for determination of just
compensation.
2) Yes. The Decision of SAC is reversed and set aside. The new just compensation for respondents
land is P2.1105517 per square meter or a total of P299,569.61
The SAC based its valuation solely on the observation that there was a "patent disparity"
between the price given to respondent and the other landowners. We note that it did not apply the
DAR valuation formula since according to the SAC, it is Section 17 of R.A. No. 6657 that
"should be the principal basis of computation as it is the law governing the matter"