7. Landbank vs CA, GR No.

118712, July 5, 1996

& DAR vs CA, GR No. 118745, July 5, 1996

Facts:
 The case involves how the government pays “just
compensation” in expropriation proceedings.
 Petitioners filed their respective motions for
reconsideration contending mainly that, contrary to the
Court’s conclusion, the opening of trust accounts in
favor of the rejecting landowners is sufficient
compliance with the mandate of RA 6657.
 Sec. 16, RA 6657. Procedure for Acquisition of Private
Lands –
xxx xxx xxx
(e) Upon receipt by the landowner of the
corresponding payment or, in case of rejection or no
response from the landowner, upon deposit with an
accessible bank designated by the DAR of the
compensation in cash or in LBP bonds in accordance
with this Act, the DAR shall take immediate
possession of the land and shall request . . .”
 Moreover, it is argued that there is no legal basis for
allowing the withdrawal of the money deposited in
trust for the rejecting landowners pending the
determination of the final valuation of their
properties.
Issue:
Whether or not the opening of trust accounts is
sufficient compliance with the mandate of RA 6657.

Ruling:
No, the opening of trust accounts is not sufficient
compliance.
The provision is very clear and unambiguous, foreclosing
any doubt as to allow an expanded construction that would
include the opening of “trust accounts” within the coverage
of the term “deposit.” Accordingly, we must adhere to the
well-settled rule that when the law speaks in clear and
categorical language, there is no reason for interpretation or
construction, but only for application. Thus, recourse to any
rule which allows the opening of trust accounts as a mode of
deposit under Section 16(e) of RA 6657 goes beyond the
scope of the said provision and is therefore impermissible.

Notes:
The rule-making power must be confined to details for
regulating the mode or proceedings to carry into effect the
law as it had been enacted, and it cannot be extended to
amend or expand the statutory requirements or to embrace
matters not covered by the statute. Any resulting discrepancy
between administrative regulations and provisions of the law
will always be resolved in favor of the basic law.
8. South Pacific Sugar Corp. vs. CA
GR No. 180462, February 9, 2011

Facts:
 1999 – the government projected a shortage of some
500,000 metric tons of sugar due to the effects of El Nio
and La Nia phenomena.
 To fill the expected shortage and to ensure stable sugar
prices, then President Joseph Ejercito Estrada issued
Executive Order No. 87, Series of 1999, facilitating sugar
importation by the private sector.
 Section 2 of EO 87 created a Committee on Sugar
Conversion/Auction to determine procedures for sugar
importation as well as for collection and remittance of
conversion fee.
 Under Section 3 of EO 87, sugar conversion is by auction
and is subject to conversion fee to be remitted by Sugar
Regulatory Administration (SRA) to the Bureau of
Treasury.
 May 3, 1999 – the Committee on Sugar
Conversion/Auction issued the Bidding Rules providing
guidelines for sugar importation. Under the Bidding
Rules, the importer pays 25% of the conversion fee
within three working days from receipt of notice of the
bid award and the 75% balance upon arrival of the
imported sugar.
 The Bidding Rules also provide that if the importer fails
to make the importation or if the imported sugar fails to
 arrive on or before the set arrival date, 25% of the
conversion fee is forfeited in favor of the SRA, to wit:
“G. Forfeiture of Conversion Fee
G.1 In case of failure of the importer to make
the importation or for the imported sugar to arrive
in the Philippines on or before the Arrival Date, the
25% of Conversion Fee Bid already paid shall be
forfeited in favor of the SRA. . .”
 Pursuant to the Bidding Rules, Sugar Mill paid 25%
of the conversion fee amounting to P14,340,000.00,
while Pacific Sugar paid 25% of the conversion fee
amounting to P28,599,000.00.
 As it turned out, Sugar Mill and Pacific Sugar (sugar
corporations) delivered only 10% of their sugar
import allocation, or a total of only 3,000 metric tons
of sugar. They requested the SRA to cancel the
remaining 27,000 metric tons of sugar import
allocation blaming sharp decline in sugar prices. The
sugar corporations sought immediate
reimbursement of the corresponding 25% of the
conversion fee amounting to P38,637,000.00.
 The SRA informed the sugar corporations that the
conversion fee would be forfeited pursuant to
paragraph G.1 of the Bidding Rules. The SRA also
notified the sugar corporations that the authority to
reconsider their request for reimbursement was
vested with the Committee on Sugar
Conversion/Auction.
RTC:
 February 26, 2002 – the Sugar corporations filed a
complaint for breach of contract and damages in the
Regional Trial Court
 RTC held that paragraph G.1 of the Bidding Rules
contemplated delay in the arrival of imported sugar,
not cancellation of sugar importation. It concluded
that the forfeiture provision did not apply to the
sugar corporations which merely cancelled the
sugar importation.
 February 7, 2007 – Atty. Raul Labay, the deputized
SRA counsel, filed a notice of appeal.
 The sugar corporations moved to expunge the notice
of appeal on the ground that only the OSG, as the
principal counsel, can decide whether an appeal
should be made.
 The OSG pointed out that in its notice of
appearance, it authorized SRA counsel
Atty. Labay to assist the OSG in this case.
 RTC granted the motion to expunge the notice of
appeal. The OSG moved for reconsideration
stressing that the OSG ratified Atty. Labays filing of
a notice of appeal. The RTC denied the OSGs motion
for reconsideration. RTC granted the sugar
corporations motion for execution
CA:
 Aggrieved, the SRA filed in the Court of Appeals a
petition for certiorari under Rule 65 seeking to set
aside the RTCs orders
  The Court of Appeals held that the deputized SRA
counsel had authority to file a notice of appeal. The
appellate court thus directed the RTC to give due
course to the appeal that Atty. Labay timely filed.
 Dissatisfied with the decision of the Court of
Appeals, the sugar corporations filed in this Court a
petition for review on certiorari.

Issue:
Whether or not petitioners are entitled for
reimbursement of the paid conversion fee.

Ruling:
No, the petitioners are not entitled for the
reimbursement of the paid conversion fee.

Plainly and expressly, paragraph G.1 identifies two

situations which would bring about the forfeiture of 25%
of the conversion fee: (1) when the importer fails to
make the importation or (2) when the imported sugar
fails to arrive in the Philippines on or before the set
arrival date.

Where the language of a rule is clear, it is the duty

of the court to enforce it according to the plain meaning
of the word. There is no occasion to resort to other
means of interpretation.
9. Cecilleville Realty and Service Corp. vs. CA
GR No. 120363, September 5, 1997

Facts: