### Facts:
Eugenio Dalauta owned a 25.2160-hectare agricultural property in Butuan City, which was subject to compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP). The Land Bank of the Philippines (LBP) offered P192,782.59 as compensation, which Dalauta rejected for being inadequately low. The case escalated through various administrative and judicial levels:
1. The DAR Adjudication Board (DARAB) affirmed LBP’s valuation.
2. Dalauta filed a petition with the Regional Trial Court (RTC), acting as a Special Agrarian Court (SAC), contesting the offer.
3. The SAC, after forming a Board of Commissioners which recommended a higher valuation and hosting a series of hearings and submissions from both parties, ruled in favor of Dalauta, substantially increasing the valuation.
4. LBP appealed to the Court of Appeals (CA), which slightly modified the SAC’s decision by removing certain damages but upholding the increased land valuation.
5. LBP then sought the Supreme Court’s review, arguing issues of jurisdiction and propriety of the SAC’s calculation of just compensation.
### Issues:
1. Did the SAC correctly assume jurisdiction over the case despite the finality of the DARAB decision?
2. Did the SAC compute just compensation for Dalauta’s property correctly according to legal standards?
### Court’s Decision:
The Supreme Court upheld the SAC’s jurisdiction, stating that it has original and exclusive jurisdiction over petitions for the determination of just compensation, and dispelled the argument that the case’s initiation beyond a 15-day period rendered the DARAB’s decision final and immutable. It also refined the computation for just compensation, aligning it with Joint Memorandum Circular No. 11, series of 2003, due to the presence of commercial trees on Dalauta’s property that warranted a one-time income valuation approach. The case was remanded to the SAC for computation alignment.
### Doctrine:
The final determination of just compensation in an expropriation case, particularly under the CARP, is a judicial function, and the RTC, sitting as a Special Agrarian Court, holds original and exclusive jurisdiction.
### Class Notes:
– Just compensation in agrarian reform cases must reflect the fair market value of the expropriated property, inclusive of factors like net income generated and potential market values.
– The jurisdictional pathway for contesting valuation under CARP progresses from administrative (DARAB) to judicial forums (SAC), emphasizing the SAC’s unique and exclusive jurisdiction.
– Legal actions for determining just compensation have a prescriptive period of ten years from the notice of coverage under Article 1144(2) of the Civil Code, with adjustments for governmental delays.
### Historical Background:
This case contextualizes the implementation of the Comprehensive Agrarian Reform Program (CARP) in the Philippines, highlighting tensions between statutory valuation mechanisms and judicial interpretations of just compensation. It illustrates the evolving jurisprudence on the balance between administrative discretion and judicial oversight in agrarian reform cases, underscoring the judiciary’s critical role in ensuring equitable land distribution and fair compensation.
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