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LBP V Del Moral G.R. No. 187307 Facts

This case involves a dispute over the computation of just compensation owed to Del Moral Inc. for lands acquired under agrarian reform. The Land Bank of the Philippines informed Del Moral that it would receive P342,917.81 based on the Department of Agrarian Reform's computation, but a trial court awarded P216,104,385.00 based on fair market value. The Supreme Court upheld this amount, finding that res judicata applied from prior appeals and that courts can deviate from formulas to ensure just compensation based on evidence and delays in payment.

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385 views1 page

LBP V Del Moral G.R. No. 187307 Facts

This case involves a dispute over the computation of just compensation owed to Del Moral Inc. for lands acquired under agrarian reform. The Land Bank of the Philippines informed Del Moral that it would receive P342,917.81 based on the Department of Agrarian Reform's computation, but a trial court awarded P216,104,385.00 based on fair market value. The Supreme Court upheld this amount, finding that res judicata applied from prior appeals and that courts can deviate from formulas to ensure just compensation based on evidence and delays in payment.

Uploaded by

Fatma Jelfa
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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LBP v Del Moral

G.R. No. 187307

FACTS:

Del Moral Inc., a domestic family corporation, was the registered owner of several parcels of land
in different municipalities in Pangasinan with a total area of 125.2717 hectares. These lands were
subjected under the coverage of the agrarian reform program operating through PD No. 27.

In 1992, the Land Bank of the Philippines (LBP) informed Del Moral of the approval of its
monetary claim with the value of P342,917.81 which was based on the computation made by the
Department of Agrarian Reform (DAR).

Del Moral contested this computation with the RTC acting as Special Agrarian Court (SAC) and
was awarded with a re-computation of the value set at P216,104,385.00 based on the fair market value of
the property at the time (2006).

DAR and LBP filed several and separate appeals to the CA but were denied. Another appeal to
the Supreme Court was filed by DAR but was also denied. In the case at bar, LBP has filed a separate
appeal to the SC.

ISSUE/S:

Whether or not:
1. The principle of res judicata applies
2. Just compensation was properly computed

HELD:

1. YES. The principle of res judicata to apply, the following requisites must concur: (1) there must
be a final judgment; (2) the court rendering it must have jurisdiction over the subject matter and
the parties; (3) it must be a judgment or order on the merits; and (4) there must be, between the
two cases, identity of parties, subject matter, and causes of action.

Hence, the petition filed by LBP must also be denied because the court has already adjudicated on
an identical case appealed by DAR. DAR and LBP having joint liability on the matter, they are
treated as the same parties on a single case. The court’s decision to deny the prior petition filed by
DAR also binds LBP.

2. YES. Although LBP contends that the formula provided by DAR-EO should control the
computation, the court reiterated that: “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.”

Hence, computation of just compensation must be made at the time of the payment especially
when there had already been a great delay in the payment of the value due to Del Moral.

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