Case Digest: LBP vs Honeycomb Farms Corp GR No 166259

Case Digest: LBP vs Honeycomb Farms Corp
GR No 166259                                                                         November 12, 2012

Facts:
Honeycomb Farms Corp. (HFC) is a registered owner of a parcel of land covered by TCT No. T-2550 with an area of 29.0966 hectares. Through a letter HFC voluntarily offered its land to the DAR for acquisition pursuant to CARP for P 581,932.00 @ P 20,000.00 per hectare. The DAR and LBP determined an acquirable and compensable area of 27.5871 hectares while the remaining were excluded for being hilly and underdeveloped.

LBP pursuant to DAR-AO No. 6 fixed the value of the land in the amount of P 165,739.44. HFC rejected the said valuation and filed with the DARAB a petition for determination of just compensation. HFC claimed that the just compensation should be in the amount of P 25,000.00 per hectare considering its location and productivity for a total of P 725,000.00.

Pending this case, HFC filed a complaint for determination of just compensation with the RTC (SAC) praying for a P 725,000.00 just compensation plus attorneys fee of 10% of the just compensation. HFC justified the filing in the RTC (SAC) for the unreasonable delay of DARAB. LBP countered that HFC's petition was premature for failure to exhaust administrative remedies.

Issue:

  1. Whether or not RTC (SAC) properly acquired jurisdiction over HFC's complaint despite pendency of the determination of just compensation with the DARAB.
  2. How much is the just compensation of the property?

Ruling:

  1. HFC correctly filed a petition for the determination of just compensation with the RTC (SAC), which has the original and exclusive jurisdiction in just compensation cases under RA 6657. The DARAB's valuation is being preliminary in nature, could not have attained finality, as only the courts cas resolve the issue of just compensation.
  2. However, the SAC committed error in applying the bais formula in determining the just compensation prescribed by DAR-AO No. 6. The case is remanded to the RTC (SAC) for determination of just compensation.

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