DIAMOND FARMS, INC.,vs.

DIAMOND FARM WORKERS administrative hearing on the determination of just

MULTI-PURPOSE COOPERATIVE compensation.

G.R. No. 192999 July 18, 2012
Facts:
Petitioner is a corporation engaged in the commercial
farming of bananas. A portion of the land it owns was placed
under CARP coverage. Thus, its certificate of title over
portions of the land under CARP were cancelled, and new
TCT’s were issued in the name of the Republic of the
Philippines. Subsequently, beneficiaries were identified, most
of whom were members of respondent cooperative.
Petitioner filed a complaint for unlawful occupation against
respondents, alleging that it was the lawful owner of two
parcels of land within the portions covered by the CLOA and
that the said CLOAs had yet to attain finality owing to appeals
filled by petitioner. Thus, while the beneficiaries had yet to be
designated with finality, respondents refused to do work for
petitioner, and forcibly entered the land subject to the
dispute and occupied the same.
Respondents argued the indeed, petitioner had the TCT’s of
the parcel of land subject to the dispute, but these were put
under the name of the Republic upon subjecting it to CARP.
Thus, despite the award of the CLOAs to respondents,
petitioner continued to manage the land while paying them
wages.
ISSUE: Whether or not the respondents are guilty of unlawful
occupation?
HELD:
NO. The CA found that petitioner has never sought the
nullification of the Republic’s TCTs. Further, the CA found no
credible evidence relating to proceedings for payment of just
compensation. The CA held that the issuance of the
Republic’s TCTs and CLOAs in favor of the 278 CARP
beneficiaries implies the deposit in cash or LBP bonds of the
amount initially determined as compensation for petitioner’s
land or the actual payment of just compensation due to
petitioner. Thus, upon it already lost possession and
ownership over the land when the payment of just
compensation was fulfilled.
During the pendency of the DARAB case, Celada filed a petition
for judicial determination of just compensation, alleging that
the current market value of her land was at least
P2,129,085.00. In its answer, Land Bank raised the affirmative
defense of non-exhaustion of administrative remedies. It
contended that Celada must first await the outcome of the
DARAB case before taking any judicial recourse. Meanwhile,
the DARAB Provincial Adjudicator affirmed the valuation made
by LandBank. Thereafter, the Special Agrarian Court (SAC),
where Celada’s petition was filed, rendered judgment fixing
the value of the land at P354,847.50, finding that Celada’s
evidence showed that the neighboring lands of similar
classification were paid higher than what was quoted by Land
Bank. It denied Land Bank’s affirmative defense. The Court of
Appeals dismissed Land Bank’s appeal.
Land Bank maintains that the SAC erred in assuming
jurisdiction over Celada’s petition for judicial determination of
just compensation despite the pendency of the administrative
proceedings before the DARAB. It also contends that the SAC
erred in fixing the just compensation of the land based on the
valuation of neighboring lands instead of its actual land use.
ISSUES: Whether or not the SAC erred in fixing the just
compensation of the land based on the valuation of
neighboring lands?
Held:
SAC erred in fixing just compensation based on valuation of
neighboring lands.
The SAC, however, erred in setting aside Land Bank’s valuation
of the land on the sole basis of the higher valuation given for
neighboring properties. It did not apply the DAR valuation
formula which considers capitalized net income, comparable
sales and market value per tax declaration as components of
land value.

LAND BANK OF THE PHILIPPINES v. LEONILA CELADA

FACTS:

Leonila Celada owns an agricultural land, 60% of which was

identified in 1998 by the DAR as suitable for compulsory
acquisition under the CARP. Land Bank valued the said land at
P299, 569.61. DAR offered the same amount to Celada as just
compensation. Celada, however, rejected the offer. The
matter was then referred to the DARAB for summary