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LAND BANK OF PHILIPPINES v. HEIRS OF MAXIMO PUYAT

This case has been cited 4 times or more.

2014-04-23
VILLARAMA, JR., J.
In Land Bank of the Philippines v. Heirs of Maximo Puyat,[28] the same doctrine was applied where the Court noted that both the taking of the landowner's property and the valuation occurred during the effectivity of R.A. No. 6657.  Since the acquisition process under P.D. No. 27 remains incomplete and is overtaken by R.A. No. 6657, the process should be completed under R.A. No. 6657, with P.D. No. 27 and E.O. No. 228 having suppletory effect only.[29]   Similarly, in Land Bank of the Philippines v. Soriano,[30] this Court held that Section 17 of R.A. No. 6657 should be the principal basis of the computation for just compensation.  While the lands involved therein were acquired under P.D. No. 27, the Court noted that the complaint for just compensation was only lodged before the court (SAC) on November 23, 2000 or long after the passage of R.A. No. 6657.
2013-08-28
PEREZ, J.
The complementary pronouncements that the formula is already a translation of the land valuation factors, such that the SAC is not at liberty to disregard the formula, had since been thereafter honored and followed. We are reminded, however, of decisions that state a principle as vital as that which enjoins the SAC from disregarding the DAR formula: The determination of just compensation is a judicial function which cannot be unduly restricted, and of which the SAC cannot be deprived. In LBP v. Heirs of Maximo Puyat,[30] we said:Land Bank maintains that, assuming arguendo that RA 6657 is the applicable law, the trial and appellate courts wantonly disregard the basic valuation formula in DAR AO No. 5, series of 1998, which implements Section 17 of RA 6657. It insists that courts are not at liberty to dispense of these formulations at will. Land Bank thus asks that the case be remanded to the trial court for a proper determination of the just compensation in accordance with DAR AO No. 5, series of 1998.
2013-07-01
PERALTA, J.
Additionally, in the more recent case of Land Bank of the Philippines v. Heirs of Maximo Puyat and Gloria Puyat,[15] the Court again adhered to the ruling laid down in the abovementioned case. Here, the Court ruled that when the government takes property pursuant to PD No. 27, but does not pay the landowner his just compensation until after RA No. 6657 has taken effect in 1998, it becomes more equitable to determine just compensation using RA No. 6657 and not EO No. 228. Hence, the valuation of the GSP of palay should be based on its value at the time it was ordered paid by the SAC.
2012-10-03
LEONARDO-DE CASTRO, J.
Elucidating on this pronouncement, this Court, in Land Bank of the Philippines v. Puyat,[47] held: In the case at bar, respondents' title to the property was cancelled and awarded to farmer-beneficiaries on March 20, 1990.  In 1992, Land Bank approved the initial valuation for the just compensation that will be given to respondents.  Both the taking of respondents' property and the valuation occurred during the effectivity of RA 6657.  When the acquisition process under PD 27 remains incomplete and is overtaken by RA 6657, the process should be completed under RA 6657, with PD 27 and EO 228 having suppletory effect only.  This means that PD 27 applies only insofar as there are gaps in RA 6657; where RA 6657 is sufficient, PD 27 is superseded.  Among the matters where RA 6657 is sufficient is the determination of just compensation.  In Section 17 thereof, the legislature has provided for the factors that are determinative of just compensation.  Petitioner cannot insist on applying PD 27 which would render Section 17 of RA 6657 inutile. (Emphases ours, citation omitted.)