Land Bank of the Philippines v.

Leonila Celada
G.R. No. 164876. January 23, 2006

Ynares-Santiago, J:

Facts:

Leonila Celada, the owner of 22.3167 hectares of agricultural land located in Calatrava,
Carmen, Bohol was identified by the Department of Agrarian Reform (DAR) to be suitable for the
compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP). Following
its identification, the DAR endorsed to the Land Bank of the Philippines (LBP) the matter for field
investigation and valuation. After the process of investigation and valuation, the LBP valued the
land at Php 299,569.61. Such amount was offered to the respondent as just compensation but it
was rejected by the same. Regardless of such rejection, LBP proceeded in depositing the same
amount to the account of Celada in cash and bonds under the latters name. Following the
procedure stated in the CARL, the mattered was referred to the DAR Adjudication Board (DARAB)
for summary administrative hearing in order to determine just compensation. While the case
under DARAB was still pending, Celada filed a petition for judicial determination of just
compensation against LBP, DAR and the Municipal Agrarian Reform Officer (MARO) before the
RTC which was the designated Special Agrarian Court (SAC). The respondent alleges that pursuan
to numerous factors, the current market value of her land is at least Php 150,000.00 per hectare.
On the other hand, the LBP filed its answer raising the non-exhaustion of administrative remedies
as well as forum-shopping as defense. The petitioner also claims that Celada must wait for the
ruling of the DARAB case before instituting such action.

Issue:

Whether or not the SAC erred in setting aside the petitioner’s valuation of the
respondent’s land on the sole basis of the higher valuation given for neighboring properties.

Held:

The court rulled in affirmative. Sac cannot ignore the administrative issuances in
determination of the just compensation of lands which are up for expropriation especially when
its validity is not in question. The petitioner under the circumstances arrived at its violation upon
application of available factors extracted from the DAR and the Philippine Coconut Authority,
using the formula provided under DAR A.O. No. 5, s, of 1998. The court found no reason to
invalidate the formula and computation and declared it to be in accordance with the law.
 Land Bank of the Philippines v. Eli Natividad
G.R. No. 127198. May 16, 2005

Tinga, J:

Facts:

The respondents filed a petition before the trial court for the determination of Just
Compensation for their agricultural land located in Arayat, Pampanga. Such lands were acquired
by the government pursuant to P.D. No. 27. The RTC hence ordered Land Bank of the Philippines
and the Department of Agrarian Reform to pay the respondent’s land for Php 30.00 per square
meter. The LBP is unable to file its motion for reconsideration on time on grounds that the motion
filed by its counsel lacked a notice of hearing. LBP argues that the failure of its counsel to file the
MR was due to intense work-pressure and constitutes excusable negligence. LBP further states
that the RTC should have applied the relief enshrined in Sec. 1 of Rule 38 of the 1997 Rules of
Civil Procedure. LBP also argues that the respondents failed to exhausted administrative
remedies when the petition for the determination of just compensation since it was filed directly
with the trial court without first seeking reconsideration of the DAR’s valuation of the property.

Issue:

Whether or not the respondents should have sought reconsideration from the DAR.

Held:

The Court ruled in negative. Since the trial court already arrived at the just compensation which
is due to the private respondents for their property, it must be understood as to have taken into
account its nature, location, market value, assessor’s value and the volume and value of produce.
The court believes that the RTC has already correctly determined the amount of just
compensation which is due to the private respondents which is in accordance with RA 6657 and
existing jurisprudence. Hence, reconsideration from the DAR is unnecessary.

Josefina Lubrica v. Land Bank of the Philippines

G.R. No. 170220. November 10, 2006

Ynares-Santiago, J:

Facts:
The petitioner, Josefina Lubrica is the assignee pf Federico Suntay over parcels of
agricultural land located at Sta. Lucia, Sablayan, Occidental Mindoro. Pursuant to PD No. 27 and
EO No. 228, the abovementioned lands were placed under land reform and were distributed
among their respective beneficiaries. The Department of Agrarian Reform (DAR) and the Land
Bank of the Philippines (LBP) set the value of land at Php 5,056.833.54 and the amount was
deposited in cash and bonds in favor of Lubrica. The lands of the other petitioners, Nerita Suntay-
Teodoro and Emilio Suntay III who inherited the land from Federico Suntay was also subjected to
the Agrarian Reform and was valued at Php 1,512,575.05. The petitioners felt that such valuation
was improper and instituted a case for judicial determination of just compensation. The case was
forwarded to the Provincial Agrarian Reform Adjudicator and valued the land belonging to
Lubrica at Php 51,800,286.43 and those belonging to Suntay and Teodoro at Php 21,608,215.28.
LBP was not pleased with the valuation of PARAD and instituted a petition for judicial
determination of just compensation before the RTC acting as a Special Agrarian Court. The RTC
granted the motion of the Petitioners and ordered LBP to deposit the amount which was
determined by PARAD.

Issue:

1. Whether or not the Court decided the case not to be in ccordance with the devision of
the Supreme Court in the case of LBP v. Natividad

Held:

No. The court ruled that the land owners were deprived use of their property in 1972. It
is required that before the actual taking of the property, just compensation must first be paid.
Also, it would be inequitable on part of the land owner if the value computed at the time of taking
in 1972 was the value used in computing for the payment.