APO FRUITS CORPORATION vs.

LANDBANK, GR 164195
FACTS:
Petitioners are registered owners of five parcels of agricultural lands located
in Davao Province, which they voluntarily offered to sell to the government.
Upon initial valuation of the LBP, petitioners considered such as unreasonably
low and inadequate as just compensation for the properties and thus rejected
the valuation. DAR then requested LBP to deposit the amounts equivalent to
the LBP valuations in the names of petitioners. Thereafter, new TCTs over the
lands were issued in the name of the Republic of the Philippines, and CLOAs
were subsequently issued to farmer-beneficiaries. Petitioners, then, filed a
complaint for the determination of just compensation with the DARAB but
despite the lapse of 10 years, the latter failed and refused to render decision
on the valuation of the disputed lands, which prompted petitioners to proceed
with the RTC as Special Agrarian Court for the determination of just
compensation. The trial court set the just compensation to be paid and fixed
the interest due on the balance of the compensation due at 12% per annum.
CA reversed the decision on appeal.
ISSUE:
Under whose jurisdiction is the determination of the final just compensation
proper?
How is the value of just compensation determined?
HELD:
It is now settled that the valuation of property in eminent domain is
essentially a judicial function which is vested with the RTC acting as Special
Agrarian Court. The same cannot be lodged with administrative agencies and
may not be usurped by any other branch or official of the government.
On the issue determination of just compensation, Section 17 of Republic Act
No. 6657, which is particularly relevant, providing as it does the guideposts
for the determination of just compensation, reads, as follows:
Sec. 17. Determination of Just Compensation. In determining just
compensation, the cost of acquisition of the land, the current value of like
properties, its nature, actual use and income, the sworn valuation by the
owner, the tax declarations, and the assessment made by government
assessors shall be considered. The social and economic benefits contributed
by the farmers and the farm-workers and by the Government to the property
as well as the non-payment of taxes or loans secured from any government
financing institution on the said land shall be considered as additional factors
to determine its valuation.

The RTC provided the following elucidation in its assailed decision:

The recommendation of the Commissioners Report for a value of P85.00 per
sq.m. or P850,000.00 per hectare (sic) is founded on evidence. The schedule
of market values of the City of Tagum as per its 1993 and 1994 Revision of
Assessment and Property Classification (Exhibit "J-6" and "CC-6") give the

lowest value for residential land at P100/sq.m. for 4th class residential land in
1993. In 1994, it gave the lowest value of P80.00/sq.m. for barangay
residential lot. It appears that certain portions of the land in question have
been classified as Medium Industrial District (Exhibit "J-4" and "CC-4"). The
lowest value as for industrial land, 3rd class in a barangay is P130.00 sq.m.
The average of these figures, using the lowest values in Exhibit "6" and "CC6" yields the figure of P103.33 which is even higher by 22.2% than that
recommended by the Commissioners. It is even of judicial notice that
assessments made by local governments are much lower than real market
value. Likewise, the value of the improvements thereon, not even considered
in the average of P103.33. If considered, this will necessarily result in a higher
average value.

Thus, the value of just compensation as determined by the trial court is

deemed proper and equitable.