DECENA Case Digest LBP V Del Moral

 

Arbiter Melchisedek Guan Agrarian Law and Social Legislation

DECENA, Elias Rafael L.

L2A, Juris Doctor

LBP v Del Moral G.R. No. 187307 FACTS: Del Moral Inc., a domestic family corporation, was the registered owner of several parcels of land in different municipalities in Pangasinan with a total area of 125.2717 hectares. These lands were subjected under the coverage of the agrarian reform program operating through PD No. 27. In 1992, the Land Bank of the Philippines (LBP) informed Del Moral of the approval of its monetary claim with the value of P342,917.81 which was based on the computation made by the Department of  Agrarian Reform (DAR). Del Moral contested this computation with the RTC acting as Special Agrarian Court (SAC) and was awarded with a re-computation of the value set at P216,104,385.00 based on the fair market value of the  property at the time (2006). (2006). DAR and LBP filed several and separate appeals to the CA but were denied. Another appeal to the Supreme to the SC.Court was filed by DAR but was also denied. In the case at bar, LBP has filed a separate appeal ISSUE/S: Whether or not: 1. The prin princip ciple le o off res judica judicata ta appl applies ies 2. Just Just compen compensat sation ion was was prope properly rly comp compute uted d HELD: 1. YES. The princip principle le of res judicata judicata to apply, apply, the follow following ing requ requisite isitess must concur: concur: (1) there there must  be a final judgment; (2) the court rendering it must have jurisdiction over the subject matter and the parties; (3) it must be a judgment or order on the merits; and (4) there must be, between the two cases, identity of parties, subject matter, and causes of action. Hence, the petition filed by LBP must also be denied because the court has already adjudicated on an identical case appealed by DAR. DAR and LBP having joint liability on the matter, they are treated as the same parties on a single case. The court’s decision to deny the prior petition filed by DAR also binds LBP. 2. YES. YES. Alth Althou ough gh LBP LBP cont conten ends ds th that at th thee fo form rmul ulaa prov provid ided ed by DAR-E DAR-EO O sh shou ould ld cont contro roll the the computation, the court reiterated that: “If, in the exercise of their judicial discretion, courts find that a strict application of said formulas is not warranted under the specific circumstances of the case before them, they may deviate or depart therefrom, provided that this departure or deviation is supported by a reasoned explanation grounded on the evidence on record. In other words, courts of law possess the power to make a final determination of just compensation.” Hence, computation of just compensation must be made at the time of the payment especially when there had already been a great delay in the payment of the value due to Del Moral.