LAND BANK OF THE PHILIPPINES, Petitioner,
vs.
LEONILA P. CELADA, Respondent.
G.R. No. 164876
January 23, 2006
Facts
Celada owns an agricultural land, 60% of which was identified in 1998 by theDepartment of
Agrarian Reform (DAR) as suitable for compulsory acquisition underthe Comprehensive
Agrarian Reform Program (CARP). Upon indorsement to it forfield investigation and valuation,
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 DAR
Adjudication Board(DARAB) for summary administrative hearing on the determination of just
compensation.
During the pendency of the DARAB case, Celada filed a petition for judicialdetermination of just
compensation, alleging that the current market value of herland was at least P2,129,085.00. In
its answer, Land Bank raised the affirmativedefense of non-exhaustion of administrative
remedies. It contended that Celadamust first await the outcome of the DARAB case before
taking any judicial recourse.Meanwhile, the DARAB Provincial Adjudicator affirmed the valuation
made by Land Bank. It also contends that the SACerred in fixing the just compensation of the
land based on the valuation ofneighboring lands instead of its actual land use
ISSUES:
1.) Whether or not the SAC erred in assuming jurisdiction over the petition for judicial
determination of just compensation pending administrative proceedings before the DARAB;
2.) Whether or not the SAC erred in fixing the just compensation of the land basedon the
valuation of neighboring lands.
RULING:
The petition is GRANTED.
The SAC did not err in assuming jurisdiction over the petition for determination of just
compensation despite the pendency of the administrative proceedings beforethe DARAB. As
the Court held in Land Bank of the Philippines v. Court of Appeals, the RTC, sitting as a SAC,
has ‘original and exclusive jurisdiction over all petitions forthe determination of just
compensation to landowners. It should be emphasized that the taking of property under the
CARP is an exerciseof the power of eminent domain by the State. The valuation of property
ordetermination of just compensation is a judicial function. Thus, the SAC properly took
cognizance of Celada’s petition for determination of just compensation. 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 applythe DAR valuation formula which considers
capitalized net income, comparablesales and market value per tax declaration as components
of land value.