Landbank v.

Yatco Agricultural Enterprises

Facts
Yatco Agricultural Enterprises (Yatco) was the registered owner of a 27.5730-hectare parcel of agricultural land
in Barangay Mabato, Calamba, Laguna.
In 1999, the government placed the property under the coverage of its Comprehensive Agrarian Reform
Program (CARP).
Pursuant to EO 405, the Landbank of the Philippines (LBP) valued the property at P1,126,132.89.
Yatco did not find this valuation acceptable and thus elevated the matter to the Department of Agrarian Reform
(DAR) Provincial Agrarian Reform Adjudicator (PARAD) of San Pablo City, which then conducted summary
administrative proceedings for the determination of just compensation.
The PARAD computed the value of the property at P16,543,800.00; it used the propertys current market value
(as shown in the tax declaration that Yatco submitted) and applied the formula MV x 2. The PARAD noted that
the LBP did not present any verified or authentic document to back up its computation; hence, it brushed aside
the LBPs valuation.
The LBP did not move to reconsider the PARADs ruling. Instead, it filed with the RTC-SAC a petition for the
judicial determination of just compensation.
The RTC-SAC fixed the just compensation for the property at P200.00 per square meter.
o The RTC-SAC arrived at this valuation by adopting the valuation set by the RTC of Calamba City, Branch
35 in Civil Case No. 2326-96-C, which, in turn, adopted the valuation that the RTC of Calamba
City, Branch 36 arrived at in Civil Case No. 2259-95-C.
o The RTC-SAC did not give weight to the LBPs evidence in justifying its valuation, pointing out that the
LBP failed to prove that it complied with the prescribed procedure and likewise failed to consider the
valuation factors provided in Section 17 of the Comprehensive Agrarian Reform Law of 1988 (CARL).
CA dismissed the LBPs appeal.
o It did not find the LBPs assigned errors the RTC-SACs reliance on the valuation made by Branches 35
and 36 in the civil cases to be persuasive.
o The parcels of land in the civil cases were the very same properties in the appealed agrarian case.
o Branch 36s valuation was based on the report of the duly appointed commissioners and was arrived at
after proper land inspection. As the determination of just compensation is essentially a judicial function,
the CA thus affirmed the RTC-SACs valuation which was founded on factual and legal bases. Hence, this
petition.

Issues
1. WoN the issues raised are factual
NO
Rule 45 does not allow the review of questions of fact. A question of fact exists when the doubt or difference
arises as to the truth or falsity of the alleged facts.
The LBP essentially questions in the present petition the RTC-SACs adoption of the valuation made by Branch 36
in fixing the just compensation for the property. The LBP asks the question: was the just compensation fixed by
the RTC-SAC for the property, which was based solely on Branch 36s valuation, determined in accordance with
law?
The issue is one of law. Resolution of this question can be made by mere inquiry into the law and jurisprudence
on the matter, and does not require a review of the parties evidence.

2. WoN the determination of just compensation is essentially a judicial function that the Judiciary exercises within
the parameters of the law
YES
Section 57 of R.A. No. 6657 explicitly vests the RTC-SAC the original and exclusive power to determine just
compensation for lands under CARP coverage. Section 17 of R.A. No. 6657 enumerates the factors required to
be taken into account to correctly determine just compensation. The law likewise empowers the DAR to issue
rules for its implementation. The DAR thus issued DAR AO 5-98 incorporating the laws listed factors in
 determining just compensation into a basic formula that contains the details that take these factors into
account.
That the RTC-SAC must consider the factors mentioned by the law (and consequently the DARs implementing
formula) is not a novel concept.

In the exercise of the Courts essentially judicial function of determining just compensation, the RTC-SACs are
not granted unlimited discretion and must consider and apply the R.A. No. 6657-enumerated factors and the
DAR formula that reflect these factors.
These factors and formula provide the uniform framework or structure for the computation of the just
compensation for a property subject to agrarian reform. This uniform system will ensure that they do not
arbitrarily fix an amount that is absurd, baseless and even contradictory to the objectives of our agrarian reform
laws as just compensation. This system will likewise ensure that the just compensation fixed represents, at the
very least, a close approximation of the full and real value of the property taken that is fair and equitable for
both the farmer-beneficiaries and the landowner.
When acting within the parameters set by the law itself, the RTC-SACs, however, are not strictly bound to apply
the DAR formula to its minute detail, particularly when faced with situations that do not warrant the formulas
strict application; they may, in the exercise of their discretion, relax the formulas application to fit the factual
situations before them. They must, however, clearly explain the reason for any deviation from the factors and
formula that the law and the rules have provided.

3. WoN RTC-SACs valuation is erroneous

YES
Judicial Notice
The taking of judicial notice is a matter of expediency and convenience for it fulfills the purpose that the evidence
is intended to achieve, and in this sense, it is equivalent to proof. Generally, courts are not authorized to take
judicial notice of the contents of the records of other cases even when said cases have been tried or are pending
in the same court or before the same judge. They may, however, take judicial notice of a decision or the facts
prevailing in another case sitting in the same court if: (1) the parties present them in evidence, absent any
opposition from the other party; or (2) the court, in its discretion, resolves to do so. In either case, the courts
must observe the clear boundary provided by Section 3, Rule 129 of the Rules of Court.
Yatco offered in evidence copies of the decisions in the civil cases, which offer the LBP opposed. These were duly
noted by the court. Even assuming, however, that the April 21, 2004 order of the RTC-SAC (that noted Yatcos
offer in evidence and the LBPs opposition to it) constitutes sufficient compliance with the requirement of
Section 3, Rule 129 of the Rules of Court, the Court finds the RTC-SACs valuation based on Branch 36s
previous ruling to be legally erroneous.

The RTC-SAC fully disregarded Section 17 of R.A. No. 6657 and DAR AO 5-98 and thus acted outside the
contemplation of the law.
After considering the factors and formula, RTC-SAC completely disregarded them and simply relied on Branch
36s valuation.
The RTC-SAC did not point to any specific evidence or cite the values and amounts it used in arriving at the
P200.00 per square meter valuation. It did not even consider the propertys market value based on the current
tax declaration that Yatco insists the RTC-SAC considered in addition to Branch 36s valuation.
Assuming that the RTC-SAC considered the propertys market value, this alone will not suffice as basis, unless
justified under Item II.A.3 of DAR AO 5-98. Then too, it did not indicate the formula that it used in arriving at its
valuation or which led it to believe that Branch 36s valuation was applicable to this case.
Lastly, the RTC-SAC did not conduct an independent assessment and computation using the considerations
required by the law and the rules.

The valuation fixed by Branches 35 and 36 was inapplicable to the property

NAPOCOR was tasked to carry out the state policy of providing electricity throughout the Philippines. In its
decision in Civil Case No. 2259-95-C, Branch 36 accordingly recognized the NAPOCORs authority to enter the
property of the defendant GP Development Corporation and to acquire the easement of right of way in the
 exercise of its powers. Thus, in disposing of the case, Branch 36 adopted the recommendation of the appointed
commissioners and ordered the NAPOCOR to pay easement fee of P20.00 per square meter. Similarly
recognizing this authority of NAPOCOR, Branch 35 in Civil Case No. 2326-96-C likewise ordered NAPOCOR to
pay easement fee of P20.00 per square meter.
The civil cases were not made under the provisions of the CARL nor for agrarian reform purposes, as enunciated
under R.A. No. 6657. In exercising the power vested in it by the provisions of C.A. No. 120, the NAPOCOR did not
seek to acquire and distribute lands to farmers and regular farmworkers; the NAPOCOR sought easement of
right of way to transmit electric power as it was tasked to.
The RTC-SAC adopted Branch 36s valuation without any qualification or condition. Yet, in disposing of the
present case, the just compensation that it fixed for the property largely differed from the former. Branch 36
fixed a valuation of P20/sq.m while RTC-SAC fixed at P200/sq.m.
In ascertaining just compensation, the fair market value of the expropriated property is determined as of the
time of taking. The decision in Civil Case No. 2259-95-C, which pegged the valuation at P20.00 per square meter,
was made in 1997. The record did not disclose when title to the land subject of that case was transferred to the
State. The Court assumed that the taking was made in 1997 (the date Branch 36 issued its decision) or at the
time of the filing of the complaint, which logically was prior to 1997.
The RTC-SAC, in the present case, rendered its decision in 2004; the LBP filed the petition for judicial
determination of just compensation in 2002. Obviously, the taking of the property could not have been made
any earlier than 2002; otherwise, the parties would have pointed these out. Between 1997 in Civil Case No.
2259-95-C and the earliest taking in 2002 in this case is a difference of 5 years a significant gap in the matter of
valuation since the lands involved are not in the hinterlands, but in the rapidly industrializing Calamba, Laguna.