Land Bank of the Philippines Vs. Del Moral, Inc. G.R. No. 187307. October 14, 2020

just compensation https://sc.judiciary.gov.ph/14863/

Nonetheless, the RTC, acting as a SAC, is reminded that it is not strictly bound by the different [formulas] created by the DAR if the situations before it do not warrant their application. To insist on a rigid application of the formula goes beyond the intent and spirit of the law, bearing in mind that the valuation of property or the determination of just compensation is essentiall y a judicial function which is vested with the courts, and not with administrative agencies. Therefore, the RTC must still be able to reasonably exercise its judicial discretion in the evaluation of the factors for just compensation, which cannot be restricted by a formula dictated by the DAR when faced with situations that do not warrant its strict application. However, the RTC must explain and justify in clear [terms] the reason for any deviation from the prescribed factors and formula.30 The determination of just compensation is a judicial function which cannot be curtailed or limited by legislation, much less by an administrative rule.3 1 Section 57 ofR.A. No. 6657 vests the Special Agrarian Courts the "original and exclusive jurisdiction over all petitions for the determination of just compensation to landowners." While Section 17 of R.A. No. 6657 requires the due consideration of the formula prescribed by the DAR, the determination of just compensation is still subject to the final decision of the proper court. We reiterated this in Alfonso v. Land Bank of the Philippines32 to wit: Out of regard for the DAR's expertise as the concerned implementing agency, courts should henceforth consider the factors stated in Section 17 of RA 6657, as amended, as translated into the applicable DAR formulas in their determination of just compensation for the properties covered by the said law. If, in the exercise of their judicial discretion, courts find that a strict application of said formulas is not warranted under the specific circumstances of the case before them, they may deviate or depart therefrom, provided that this departure or deviation is supported by a reasoned explanation grounded on the evidence on record. In other words, courts of law possess the power to make a final determination of just compensation. [Emphas is supplied.] Thus, the CA correctly affinned the findings of the RTC. The LBP's argument on mandatory adherence to the provisions of the law and administrative orders must fail. The RTC's judgment must be given due respect as an exercise of its legal duty to arrive at a final determination of just compensation.