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CASE DIGEST

Written By: SULLANO, Gavriil


Case Name: LBP v. WYCOCO
Doctrine:
While market value may be one of the bases of determining just compensation, the same cannot
be arbitrarily be arrived at without considering he factors to be appreciated in arriving at the fair
market value of the property.
Facts:
Feliciano Wycoco is the registered owner of a 94-hectare unirrigated and untenanted rice
land situated in Sitios Ablang, Saguing and Pinamunghilan, San Juan, Nueva Ecija.
Upon the passage of the CARP(Comperehensive Agrarian Reform Law), Wycoco
voluntarily offered to sell his land with the DAR for P14.9M.
Upon DARs evaluation, Wycoco received a letter informing him that the
DAR intended to acquire 84-hectares of his land for P1.34M amount was
subsequently raised to P2.30M
Wycoco rejected the offer, prompting the DAR to indorse the case to the DARAB to fix
the amount of just compensation due.
DARAB requested LBP to open a trust account under Wycoco
In the meantime, the propery was distributed to the farmer-beneficiaries.
In 93 Respondent filed a manifestation informing the DARAB of the pendency of their
Agrarian Case with the Special Agrarian Court of Cabanatuan
Trial Courts ruling: Ordered Land Bank to pay Wycoco P13.4M as just compensation
CAs ruling: Affirmed the decision with slight modifications on the value.
Issue:
1. WON the RTC, acting as Special Agrarian Court,properly acquired jurisdiction over the
instant case for the determination of just compensation
2. WON the compensation arrived at supported by evidence
Ruling:
WHEREFORE, in view of all the foregoing, the petition in G.R. No. 140160 is PARTIALLY
GRANTED. Agrarian Case No. 91 (AF) is REMANDED to the Regional Trial Court of
Cabanatuan City, Branch 23, for the determination of just compensation.

In accordance with Section 57 of the CARP, the RTC, sitting as a Special Agrarian Court,
has an original and exclusive jurisdiction over all petitions for the determination of just
compensation to landowners.
With regard to the valuation of the property, the Court held that the trial court should
have allowed the parties to present evidence thereon instead of practically assuming a
valuation without basis.
While market value may be one of the bases of determining just
compensation, the same cannot be arbitrarily be arrived at without
considering he factors to be appreciated in arriving at the fair market value of
the property. (e.g size, shape, location etc)

Verily, the trust account opened by LBP to in the name of Wycoco as the mode of
payment of just compensation should be converted to a deposit account.
The interest earnings accruing on the deposit account of landowners would
suffice to compensate their pending payment of just compensation.
Just compensation due to Wycoco should include a 12% interest/annum from
the time LBP opened a trust account until said account was converted into
cash.
The basis of the 12% would be the just compensation to be determined by the
Special Agrarian Court.
The same shall also be the basis of the interest income on the cash and bond
deposit due to Wycoco.