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CONSTITUTIONAL LAW 2 and by the government to the property, and the

non-payment of taxes or loans secured from any


government financing institution on the said land,
if any, must be equally considered.
DAR v. STO ROMANA
G.R. No. 183290. July 9, 2014. Just compensation must be valued at the time of taking, or
the time when the landowner was deprived of the use and
DOCTRINE: In coming up with the correct benefit of his property, such as when title is transferred in the
and proper valuation of properties for name of the Republic of the Philippines. Hence, the
the purposes of expropriation, the evidence to be presented by the parties before the trial court
standards provided in CARP must be for the valuation of the subject land must be based on
followed and other laws providing for the values prevalent on such time of taking for like
such is only suppletory to it. agricultural lands.
The Facts
The evidence must conform with Section 17 of RA 6657, as
 Respondents are the owners of a 27K hectares of amended, prior to its amendment by RA 9700. It bears
agricultural land Nueva Ecija which DAR pointing out that while Congress passed RA 9700 on July 1,
compulsorily acquired a 21.2192-ha. portion 2009, amending certain provisions of RA 6657, as amended,
under the government's "Tenants Emancipation among them, Section 17, and declaring "(t)hat all previously
Decree,". acquired lands wherein valuation is subject to challenge by
 the LBP fixed the value of the subject land at landowners shall be completed and finally resolved pursuant
P361,181.87 using the formula under EO 228i to Section 17 of [RA 6657], as amended," the law
 Respondents were dissatisfied with the LBP should not be retroactively applied to pending claims/cases.
valuation so they filed a Petition for Approval and
In fact, DAR AO 2, series of 2009, implementing RA 9700,
Appraisal of Just Compensation before the RTC
expressly excepted from the application of the amended
arguing that the valuation was grossly inadequate
and it is way below the FMV. Section 17 all claim folders received by LBP prior to July 1,
 LBP insisted on the correctness of the valuation, 2009, which shall be valued in accordance with Section 17
having been computed in accordance with the of RA 6657, as amended, prior to its further amendment
formula under EO 228 which governs the by RA 9700.
determination of just compensation due a
landowner whose property was seized under PD With this in mind, the Court, cognizant of the fact that the
27. For its part, the DAR maintained that the instant petition for review on certiorari was filed on July 21,
proper procedure relevant to the determination 2008, or long before the passage of RA 9700, finds
of the valuation was followed. that Section 17 of RA 6657, as amended, prior to its further
 RTC appointed commissioners for the valuation amendment by RA 9700, should control the challenged
and ruled in favor of the respondents. CA valuation. In the event that the respondents had already
Affirmed. withdrawn the amount deposited by the LBP, the withdrawn
amount should be deducted from the final land valuation to
ISSUE: WON THE VALUATION OF THE PROPERTY
be paid by LBP.
WAS JUST and PROPER. YES. THE RULE ON
VALUATION ON CARP MUST BE FOLLOWED.
3. The Regional Trial Court may impose interest on the just
 Settled is the rule that when the agrarian reform compensation award as may be warranted by the
process is still incomplete, as in this case where circumstances of the case. In previous cases, the Court has
the just compensation for the subject land allowed the grant of legal interest in expropriation cases
acquired under PD 27 has yet to be paid, just where there is delay in the payment since the just
compensation should be determined and the compensation due to the landowners was deemed to be an
process concluded under RA effective forbearance on the part of the State. Legal interest
6657(CARP), with PD 27 and EO 228 having mere shall be pegged at the rate of 12% interest per annum (p.a.),
suppletory effects. from the time of taking until June 30, 2013 only. Thereafter,
 In addition, the factors enumerated under Section or beginning July 1, 2013, until fully paid, the just
17 of RA 6657, the acquisition cost of the land, the compensation due the landowners shall earn interest at the
current value of like properties, the nature and new legal rate of 6% interest p.a. in line with the amendment
actual use of the property, and the income
introduced by BSP-MB Circular No. 799, series of 2013.
therefrom, the owner's sworn valuation, the tax
declarations, the assessment made by government
assessors, the social and economic benefits
contributed by the farmers and the farmworkers,

i PAYMENT BY THE FARMER BENEFICIARY AND MODE OF COMPENSATION TO THE


DECLARING FULL LAND OWNERSHIP TO QUALIFIED FARMER BENEFICIARIES COVERED LANDOWNER|||
BY PRESIDENTIAL DECREE NO. 27; DETERMINING THE VALUE OF REMAINING UNVALUED
RICE AND CORN LANDS SUBJECT TO P.D. NO. 27; AND PROVIDING FOR THE MANNER OF