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    Land Bank of The Philippines v. Eusebio, Jr. (G.r. No. 160143)

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    Villar John Ezra
    The RTC-SAC committed grave abuse of discretion in determining just compensation for expropriated land. [1] The owner of 790 hectares of land offered to sell it to the government but negotiations failed. [2] The government took possession and distributed the land, valuing it at PHP 3-19.5 million while the owner sought PHP 25 million. [3] The RTC-SAC awarded PHP 25 million based solely on conscience rather than the legal factors and formula, constituting grave abuse of discretion requiring reversal.

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    Land Bank of The Philippines v. Eusebio, Jr. (G.r. No. 160143)

    Uploaded by

    Villar John Ezra
    195 views1 page
    The RTC-SAC committed grave abuse of discretion in determining just compensation for expropriated land. [1] The owner of 790 hectares of land offered to sell it to the government but negotiations failed. [2] The government took possession and distributed the land, valuing it at PHP 3-19.5 million while the owner sought PHP 25 million. [3] The RTC-SAC awarded PHP 25 million based solely on conscience rather than the legal factors and formula, constituting grave abuse of discretion requiring reversal.

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    Land Bank of the Philippines v. Eusebio, Jr. (g.r. No. 160143)

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    The RTC-SAC committed grave abuse of discretion in determining just compensation for expropriated land. [1] The owner of 790 hectares of land offered to sell it to the government but negotiations failed. [2] The government took possession and distributed the land, valuing it at PHP 3-19.5 million while the owner sought PHP 25 million. [3] The RTC-SAC awarded PHP 25 million based solely on conscience rather than the legal factors and formula, constituting grave abuse of discretion requiring reversal.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    195 views1 page

    Land Bank of The Philippines v. Eusebio, Jr. (G.r. No. 160143)

    Uploaded by

    Villar John Ezra
    The RTC-SAC committed grave abuse of discretion in determining just compensation for expropriated land. [1] The owner of 790 hectares of land offered to sell it to the government but negotiations failed. [2] The government took possession and distributed the land, valuing it at PHP 3-19.5 million while the owner sought PHP 25 million. [3] The RTC-SAC awarded PHP 25 million based solely on conscience rather than the legal factors and formula, constituting grave abuse of discretion requiring reversal.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    LAND BANK OF THE PHILIPPINES V. EUSEBIO, JR. (G.R. NO.

    160143)

    Facts:

    Respondent Eusebio, Jr., owner of a 790.4-hectare parcel of land situated in Masbate, voluntarily
    offered to sell his land to the government through the Department of Agrarian Reform for P19.5 million.
    DAR offered to purchase the land for P3 million but it was rejected by respondent. Petitioner Land Bank
    of the Philippines (LBP) made a revaluation of the land but was rejected again by respondent.
    Meanwhile, LBP opened a trust account in favor of Eusebio, and then the DAR immediately took physical
    possession of the property, had the TCT cancelled in favor of the Republic of the Philippines, and
    distributed the property to the farmer-beneficiaries. The parties then referred the determination of just
    compensation with the Department of Agrarian Reform Adjudication Board (DARAB). Respondent still
    finding the valuation unacceptable, filed before the RTC-Special Agrarian Court an action for
    determination and payment of just compensation against DAR and LBP. During trial, separate valuation
    reports were submitted, with the DAR and LBP using the guidelines/formula under RA 6657 in their
    computation. In its judgment, the RTC-SAC brushed aside the valuations fixed by DAR and LBP, and
    found instead as considerable just compensation the amount (P25 million) prayed for by respondent.
    Both parties appealed, but CA affirmed the judgment in toto.

    Issue:

    Whether the RTC-SAC committed grave abuse of discretion in the determination of just compensation
    for the property.

    Ruling: YES.

    The determination of just compensation is essentially a judicial function that the Courts exercise within
    the parameters of the law; the RTC-SAC’s valuation in this case is erroneous for having been rendered
    outside the contemplation of the law.

    In the exercise of the essentially judicial function of determining just compensation, the RTC-SAC is not
    granted unlimited discretion. It must consider and apply the R.A. No. 6657-enumerated factors and the
    DAR formula (provided in DAR AO 6-92, as amended by DAR AO 11-94 and, by DAR AO 5-98) as they
    provide the uniform framework or structure by which just compensation for property subject to agrarian
    reform should be determined.

    A determination of just compensation based merely on “conscience” – a consideration entirely outside


    the contemplation of the law – is the precise situation that we find in this case. To be clear, other than in
    “conscience,” the RTC-SAC did not point to any particular consideration that impelled it to set the just
    compensation at ₱25 million. This absence of basis convinced us that the RTC-SAC completely, even
    arbitrarily, relied on the amount that respondent prayed for in their complaint in fixing the property’s
    just compensation. This blind reliance on respondent’s prayer and the utter disregard of the prescribed
    factors and formula clearly amount to grave abuse of discretion for having been taken outside the
    contemplation of the law.

    Thus, for grave abuse of discretion, the just compensation of ₱25 million that the RTC-SAC fixed for
    Eusebio’s property. The court is also remanded to the RTC-SAC.

    The court also set aside, for grave error, the CA’s decision that affirmed in toto this RTC-SAC’s valuation.

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