Land Bank vs. Heirs of Puyat, G.R. No.

175055, 27 June 2012

Del Castillo, J.

FACTS: Respondents were the heirs of Gloria and Maximo Puyat, registered owners of a parcel of
riceland placed under DAR’s Operation Land Transfer pursuant to PD 27, where the latter issued
several emancipation patents in favor of various farmer-beneficiaries that resulted to the patents’
annotations on Puyats’ TCT and caused its concomitant partial cancellation thereof. However, the
Puyats did not receive any compensation for the cancellation of their title over the awarded
portions of the subject property. It was only after two years that DAR instructed LBP to pay just
compensation which the Puyats rejected for being ridiculously low.

ISSUE: (1) Can the lands acquired pursuant to PD 27 be valued using the factor appearing in RA
6657?

RULING: The Court held that since the agrarian reform process was still incomplete as the just
compensation to be paid private respondents has yet to be settled, and considering the passage of
RA 6657, such just compensation should be determined and the process concluded under the later
law. As has been held in several decisions, when the government takes property pursuant to PD 27
but does not pay the landowner his just compensation until after RA 6657 has taken effect in 1988,
it becomes more equitable to determine the just compensation using RA 6657. Just compensation
should be the full and fair equivalent of the property taken from its owner by the expropriator, the
equivalent being real, substantial, full, and ample.