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CARL (R.A. 6657, as amended) and Related Laws
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FUNDAMENTAL DISTINCTIONS AMONG TENANCY, TENANT EMANCIPATION DECREE AND CARP

LEASEHOLD TENANCY TENANT EMANCIPATION DECREE COMPREHENSIVE AGRARIAN REFORM
PROGRAM

I LEGAL BASIS:
1. Republic Act No. 3844 Agricultural
Land Reform Code (August 8, 1963)
2. Republic Act No. 6389 Code of
Agrarian Reform (September 10, 1971)
3. Presidential Decree No. 1425
Amending Presidential Decree No.
1040 by Strengthening the Prohibition
against Agricultural Share Tenancy and
Providing Penalties for Violation thereof.
(June 10, 1978)
4. Section 12, Republic Act No. 6657
Comprehensive Agrarian Reform Law
of 1988.
II JURISPRUDENCE ON CONSTITUTIO-
NALITY
1. Security of Tenure Primero vs. CAR,
101 Phil. 675 (1957); Pineda vs. de Guzman,
21 SCRA 1450 (1967).

1. Presidential Decree No. 27
Tenants'
Emancipation Decree (October 21,
1972)
2. Letter of Instructions No. 474-PLACING
UNDER OLT TENANTED
RICE/CORN LANDS SEVEN
HECTARES OR LESS IN AREAS
UNDER CERTAIN CONDITIONS
(OCTOBER 21, 1976)

1. Presidential Decree No. 27 was
assumed to be constitutional and
upheld as part and parcel of the
law of the land in De Chavez vs.
Zobel, 155 SCRA 26; Gonzales vs.
Estrella, 91 SCRA 294
(1979) andAssociation of Small
Landowners in the Philippines Inc.
vs. Secretary of Agrarian Reform,
175 SCRA 342 (1989)
1. Presidential Proclamation No. 131-Instituting
a Comprehensive Agrarian Reform
Program (July 22, 1987)
2. Republic Act No. 6657 An Act instituting a
Comprehensive Agrarian Reform Program
to Promote Social Justice and
Industrialization, providing the Mechanism
for its Implementation and other purposes.
(June 15, 1988)
1. The power of President Aquino to
promulgate Proc. No. 131 and E.O.
Nos. 228and 229 was authorized
under Section 6 of the Transitory
Provision of the1987 Constitution.
All assaults against the validity
of RA 6657 were set aside.
(Association of Small Landowners in
the Philippines, Inc. vs. Secretary of
Agrarian Reform, 175 SCRA 342
(1989)
COVERAGE OF CARL 1988
III COVERAGE OR SCOPE
Agricultural Leasehold shall apply to all
tenanted agricultural lands, including but not
limited to the following
A. Retained areas under R.A. 6657 andP.D.
27;
B. Tenanted Agricultural Lands not yet
acquired for distribution under CARP
pursuant to RA 6657;
C. All tenanted areas under Section 10
ofRA 6657 which may be covered by this
Order. (Administrative Order No. 4, Series
of 1989)
IV AREA OF COVERAGE
It shall be unlawful for the tenant,
whenever the area of his holding is five
hectares or more, or is of sufficient size to
make him and the members of his
immediate farm household fully occupied in
its cultivation, to CONTRACT TO WORK at
the same time on TWO OR MORE
SEPARATE HOLDINGS belonging todifferent
landholders under any system of
tenancy WITHOUT THE KNOWLEDGE AND
CONSENT of the landholder with whom he first
entered into tenancy relationship. (Par. 1, Sec.
24, Republic Act No. 1199)
V EXEMPTION OR EXCLUSION FROM
COVERAGE
Absence of any of the six (6) Essential
Elements of Tenancy Relationship.
Essential Elements of Tenancy
Relationship:
1. The parties are the landholder and
2. Letter of Instructions No. 474;
Constitutionality was upheld
inZurbano vs. Estrella, 137 SCRA
333 (1989)
The REQUISITES FOR COVERAGEunder
OPERATION LAND TRANSFER (OLT)
program are the following:
1. The land must
be DEVOTED toRICE or CORN crop
s; and
2. There must be a system ofSHARE
CROP or LEASE
TENANCY obtaining therein.
If either of these requisites
isABSENT, the land is NOT COVERED
under OLT. Hence, a landownerNEED
NOT APPLY FOR RETENTION, where his
ownership over the entire landholding
is INTACT andUNDISTURBED. (Eudosia
Daez and/or Her Heirs represented by
Edriano D. Daez vs. the Hon. CA, et al.,
325 SCRA 857).
RULES ON COVERAGE OF LANDS
UNDER PD 27.
Rule 1
Landed estates or
landholdings larger than 24
hectares (LOI 46 (December 7,
1972) - covered by OLT and there
is no retention to the landowner.
Rule 2
Landholding of 24 hectares or less
(but above 7 hectares (LOI
46 (ibid) and LOI 227(November
16, 1974) covered by OLT but
landowner is entitled to
Scope
All PUBLIC and PRIVATE Agricultural Lands
regardless oftenurial
arrangement and commodity produced,
including lands of the public domain suitable
for agriculture. (1st par., Sec. 4, RA 6657)
Specific lands covered by CARP.
a. All alienable and disposable lands of
the public domaindevoted to or
suitable for agriculture
b. All lands of the public domain in
excess of the specific limits as
determined by Congress in the
preceding paragraph;
c. All other lands owned by the
Government devoted to or suitable for
agriculture; and
d. All private lands devoted to or suitable
for agricultureregardless of the
agricultural products raised or that
can be raised thereon.

PRIORITIES The DAR, in coordination
with the PARC, shall plan
and program the acquisition anddistribution of
all agricultural lands through a period of ten (10)
years from the effectivity of this Act. Land shall
be acquired and distributed as follows:
Phase One:
1. Rice and corn land under PD 27;
2. Idle and abandoned lands
3. Private lands voluntarily offeredby the
owners for agrarian reform;
4. Foreclosed land by governmentfinancial
institutions;
5. Land acquired by
the PresidentialCommission on
thetenant;
2. The subject is agricultural land;
3. There is consent;
4. The purpose is agricultural production;
5. There is personal cultivation;
6. There is sharing of harvest or payment of
rentals. (Caballes vs. DAR, 168 SCRA
247; Qua vs. Court of Appeals, 198 SCRA
247.)
VI RETENTION
In Leasehold Tenancy, the Landowner or
agricultural lessor RETAIN OWNERSHIPof the
subject landholding.
The
landowner EXERCISES the ATTRIBUTES OF
OWNERSHIP. Under Art. 428 of the New Civil
Code, the OWNER has the RIGHT TO DISPOSE
OF a thing without other limitation than those
imposed by law. As an incident of
ownership. Therefore, there is nothing to prevent a
landowner from DONATING his NAKED TITLE
TO THE LAND. However, the new owner MUST
RESPECT THE RIGHT OF THE TENANT.
The agricultural leasehold relation under
this Code shall not be extinguished by MERE
EXPIRATION OF THE TERM OR PERIOD in a
leasehold contract nor by theSALE,
ALIENATION OR TRANSFER of the legal
possession of the landholding. In case the
agricultural lessor SELLS, ALIENATES, OR
TRANSFERS the legal possession of the
landholding, the PURCHASER OR
TRANSFEREE thereof shall be subrogated to
the rights and substituted to the
obligations of the agricultural lessor. (see.
10, RA 3844)
retention except if LOI 474 (October
21, 1976) applies.
Rule 3
Landholding of seven (7) hectares or
less is EXEMPTED from OLT except
if LOI 474 is applicable under the
following circumstances:
Landowner owns other
agricultural land of more than
seven hectares in aggregate area,
or he ownsCOMMERCIAL,
INDUSTRIAL, RESIDENTIAL or
URBAN LAND where he derives an
adequate income, DAR Memo,
Circular No. 11, s. 1978 (April 21,
1978) Adequate income is at least
FIVE THOUSAND (P5000.00)
PESOS per annum. (Gross Income).
Lands not covered by Presidential Decree
No. 27.
1. Private agricultural lands which
are NOT PRIMARILY
DEVOTED TO RICE OR
CORN, or
2. There is NO SYSTEM OF SHARE
CROP OR LEASE
TENANCY obtaining in the
landholding. (Daez vs. CA, ibid)
* The REQUISITES for the exercise by the
landowner of his RIGHT OF
RETENTION are the following:
1. The land must be DEVOTED TO
RICE OR CORN CROPS;
2. There must be a system ofshare-crop
or lease tenancyobtaining there.
GoodGovernment; and
6. All other lands owned by the
Government devoted to or suitable for
agriculture.
These shall
be acquired anddistributed immediately
upon effectivity of the Act, with the
implementation to be completedwithin a
period of not more than four (4) years.
(Sec. 7, par. 2, RA 6657)
Phase Two:
1. All disposable and alienable public
agricultural lands;
2. All arable public agricultural lands under
agro-forest, pasture and agricultural leases
already cultivated and planted for crops in
accordance with Sec. 6, Art. XIII of the
Constitution;
3. All public agricultural lands which are open
for new development and resettlement; and
4. All private agricultural lands in excess of
fifty (50) hectares
These shall be distributed immediately
upon the effectivity of the Act, with the
implementation to be completed within a period
of not more than four (4) years.
Phase Three:
All private AGRICULTURAL LANDS
commencing with LARGE landholdings and
proceeding to MEDIUM and SMALLlandholdings
under the following schedules:
a) Landholdings ABOVE 24 hectares up to 50
hectares to begin on the fourth year from
effectivity of this Act and to be completed
VII BENEFICIARIES
The beneficiaries under Republic Act No.
1199, Republic Act No. 3844 as amended
by Republic Act No. 6389areSHARE-TENANT
OR AGRICULTURAL LESSEES
(TENANTS). Thus:
In the INTERPRETATION AND
ENFORCEMENT of this Act and other
laws as well as of the stipulations between
the landholder and the tenant the
COURTS AND ADMINISTRATIVE
OFFICIALS SHALL RESOLVE ALL
GRAVE DOUBTS IN FAVOR OF THE
TENANT. (Sec. 56, Republic Act No.
1199)
VIII AWARD CEILING
The share-tenant/ agricultural lessee who
is already cultivating a landholding with an area
of FIVE (5) HECTARES or more or
ofsufficient size to make him and member of
his immediate farm household fullyoccupied in
its cultivation is prohibited toCONTRACT TO
WORK at the same time to two or more
separate holdings belonging to different
landholders WITHOUT THE KNOWLEDGE
AND CONSENT OF THE
LANDOWNER/AGRICULTURAL
LESSOR (Par. 1, Sec. 24, Republic Act No.
1199)
IX PAYMENT FOR THE COST OF THE
LAND
In the exercise of RIGHT OF PRE-
EMPTION by the agricultural lessee-tenant, he
must EITHER TENDER PAYMENT OF, OR
PRESENT A CERTIFICATE FROM THE
LBPthat it shall make payment under Section
80 of Republic Act No. 3844 (10% CASH and
90% in six percent, tax free, redeemable bonds
issued by the LBP.) If the landowner refuses
3. The size of the landholding MUST NOT
EXCEED TWENTY FOUR (24)
hectares provided that at least seven
(7) hectares thereof are covered
lands and more than seven (7)
hectares of it consist of other
agricultural lands. Daez vs. CA,
Ibid)
Right of Retention by Landowners
under Presidential Decree No. 27.
Supplemental Guideline A.O. No. 04,
Series of 1991).
The policy statements are as
follows:
a. Landowners covered by PD 27are
entitled to retain SEVENhectares,
except those whose entire tenanted
rice and corn lands are subject to
acquisition and distribution under
OLT.
AN OWNER MAY NOT RETAIN
UNDER THE FOLLOWING CASES:
a) If he, as of October 21, 1972,
owned more than 24 hectares of
tenanted rice or corn lands; or
b) By virtue of LOI 474, if he, as of
21 October 1972, owns less
than 24 hectares of
tenanted rice but additionally
owns the following =
Other agricultural land of
more than seven hectares,
whether tenanted or not,
whether cultivated or not, and
regardless of the income derived
therefrom; or
Land used forcommercial,
industrial, residential or
within three years; and,
b) Landholdings from the RETENTION LIMIT up
to 24 hectares, to begin on the sixth year
from effectivity of this Act and to be
completed within four years.
LANDS NOT COVERED BY CARP
1. Those which are not suitable for agriculture
or those which are classified as mineral,
forest, residential, commercial or industrial
lands. (Sec. 3. (c), RA 6657);
2. Those which have been classified and
approved as NON-AGRICULTURAL prior
to June 15, 1988. (DOJ Opinion No. 44, S.
1990)
3. Those which are EXEMPT pursuant to Sec.
10, RA 6657.
4. Those which
are devoted to poultry,swine or livestock
-raising as of June 15, 1988 pursuant to
the Supreme Court ruling on Luz Farms vs.
The Hon. Secretary of Agrarian Reform
(192 SCRA 51);
5. Fishponds and prawn farms exempted
pursuant to R.A. No. 7881, and its
implementingAdministrative Order No. 3,
Series of 1995;
6. Those which are retained by thelandowners;
7. Those lands or portions thereof under the
coverage of EO 407 but found to be no
longer suitable for agriculture and
therefore could not be given appropriate
valuation by the LBP as determined by
DAR/LBP; and
to accept TENDER orPRESENTMENT, the
agricultural lessee mayCONSIGN it in COURT,
(Sec. 11, Republic Act No. 3844 as amended
by Republic Act No. 6389.
The REDEMPTION PRICE shall be the
REASONABLE PRICE OF THE LAND at the
time of sale. (Sec. 12, Republic Act No.
3844as amended by Republic Act No. 6389)
X TRANSFERABILITY OF
LANDHOLDING
1. Sale, Alienation or Transfer of the legal
possession of the landholding
2. Extinguishment of Agricultural Leasehold
Relations (Sec. 8, RA 3844)
A. ABANDONMENT of the landholding
without the knowledge of the agricultural
lessor. (Teodoro vs. Macaraeg, 27 SCRA
7 (1969) To constitute abandonment there
must be an absolute relinquishment of the
premises of the tenant. This "overt act"
must be coupled with his intention to do so
"which is carried into effect." (Philippine
Labor and Social Legislation, Martin, 70
Ed. Pp. 405-406). Abandonment to validly
terminate tenancy relationship is
characterized by:
(a) an INTENT to ABANDON, and
(b) an OVERT ACT to carry out such
intention
There must be, therefore, NO
ANIMUS REVERTENDI on the part of
the tenant.(Labor, Agrarian and Social
Legislation, Montemayor, 2nd Ed.,
other urban purposes, from
which he derives adequate
incometo support himself and
his family.
b. Landowners who filed their application
for retentionBEFORE 27 August
1985, the deadline set
by Administrative Order No. 1, Series
of 1985,may retain not more than
seven hectares of their landholding
covered by PD 27regardless of
whether or not they complied
with LOI Nos. 41,45, and 52.
Landowners who filed their
application AFTER 27 August 1985
but complied with the requirement
of LOI No. 41, 45and 52 shall
likewise beentitled to such a seven-
hectare retention area.
However, landowners who filed
their application for
retention AFTER the 27 August 1985
deadline and DID NOT
COMPLY with the requirements
of LOI Nos. 41, 45, and 52 shall only
be entitled to a maximum of five (5)
hectares as retention area.
c. A landowner WHO HAS DIEDmust
have manifested during his lifetime
his intention to exercise his right
of retention prior to 23 AUGUST
1990 (The finality of the Supreme
Court decision in the case
"Association of Small Landowners of
the Philippines, Inc. et al. vs.
Honorable Secretary of Agrarian
Reform) toallow his heirs to now
exercise such right under these
Guidelines. Said heirs must show
proof of the original landowner's
intention.
8. Those lands declared byPresidential
Proclamations for certain uses other than
agricultural.
Rules and Procedures Governing the Exercise
of Retention Rights byLandowners and Award
to Childrenunder Sec. 6 of RA 6657 (A.O. No.
11, Series of 1990; and A.O. No. 2, S. 2003)
A. Landowners whose landholdings are covered
by CARP may retainan area of FIVE
(5) hectares.
In addition, each of his children,
(legitimate, illegitimate or adopted, may
be AWARDEDthree (3) hectares
as PREFERRED BENEFICIARY provided -
1. That the child was at least 15 years of
age on June 15, 1988 (RA
6657 effectivity); and
2. The child was actually tilling the
land or directly managing the farmland
from June 15, 1988 to the filing of the
application for retention and/or at the
time of acquisition of the land under
CARP.
Retention of husband and wife:
1. For marriages covered by the New Civil
Code, the spouse who owns
only CONJUGAL PROPERTIES may
retain a total of five (5) hectares unless
there is an agreement for the JUDICIAL
SEPARATION OF PROPERTIES.
However, if either or both of them are
landowners in their respective rights
(capital and/or paraphernal), they may
retain not more than five (5) hectares
each from their respective landholdings. In
no case, however, shall the total retention
of such a couple exceed 10 hectares, and
1968, pp. 54-55)
B. VOLUNTARY SURRENDER of the
landholding by the agricultural lessee,
written notice of which shall be served
three months in advance (Nisnisan, et al.,
vs. CA, 294 SCRA 173 (1998).
As a mode of extinguishing tenancy
relationship it connotes a decision in the
part of the tenant to return the possession
of the landholding and relinquish his right
as tenant thereon uninfluenced by any
compelling factor, coming particularly from
the landholder. For surrender to be valid,
there must be (a) an intention to abandon,
and (b) an external act or an omission to
act, by which such intention is carried out
into effect. When a tenant voluntarily
yields the land, he terminates the tenancy
relationship by his unilateral act. (Anacleto
Inson vs. Planas de Asis, et al., CA GR
No. Sp-01769, October 11, 1974)
NOTE: SUBLEASING by the agricultural
lessee is also a ground for the extinguishments
of Agricultural Leasehold Relations. (Par. 2,
Sec. 27, Republic Act No. 3844)
XI EVIDENCE OF RIGHT/TITLE OVER
THE LANDHOLDING.
AGRICULTURAL LEASE-HOLD CONTRACT
IN GENERAL.
The agricultural lessor and
theagricultural lessee shall
be FREE to ENTERinto any kind
of TERMS, CONDITIONS orSTIPULATIONS in
a LEASEHOLD CONTRACT as long as
they are not contrary to LAW, MORALS OR
PUBLIC POLICY. (Sec. 15, Republic Act No.
3844).
Except in case
of mistake, violence,intimidation, undue
The heirs may also exercise the
original landowner's right of retention
if they can prove that the
decedent HAD NO KNOWLEDGE of
OLT coverage over the subject
property.
The BENEFICIARIES ofPresidential
Decree No. 27 are TENANT-FARMERS,
thus:
This shall apply to TENANT-
FARMERS of PRIVATE
AGRICULTURAL LANDS
PRIMARILY DEVOTED TO RICE OR
CORN under a SYSTEM OF
SHARE-CROP or LEASE-
TENANCY, whether classified as
landed estate or not. (Par.
5,Presidential Decree No. 27)

The tenant-farmers, whether in
land classified as landed estate or
not shall beDEEMED OWNER of a
portion constituting a family-size
farm of FIVE (5) hectares if not
irrigated and THREE (3)
HECTARES IF IRRIGATED. (Par.
6, Presidential Decree No. 27)

The tenant shall pay for THE COST
OF THE LAND, includinginterest of
six (6) percent per annum in
FIFTEEN (15) YEARS of fifteen (15)
equal annual amortizations.

NOTE: The period is extended to twenty
(20) years equal annual amortizations
under Sec. 6, E.O. 228of July 17, 1987 by
Pres. Corazon C. Aquino.
The TITLE to the landowned by
the tenant shall not be transferable
except BY HEREDITARY
2. For marriages covered by the New Family
Code (August 3, 1988), a husband owning
capital property and/or a wife owning
paraphernal property may retain not more
than five (5) hectares each provided
they execute a JUDICIAL SPERATION
OF PROPERTIES prior to entering the
marriage. In the absence of such an
agreement all properties (capital,
paraphernal and conjugal) shall be
considered held in absolute community.
QUALIFIED BENEFICIARIES. The lands
covered by the CARP shall be distributed as
much as possible tolandless residents of
the same barangay, or in the absence thereof,
landless residents of the same municipality in
the following order of priority:
a) agricultural lessees and share tenants;
b) regular farmworkers;
c) seasonal farmworkers;
d) other farmworkers;
e) actual tillers or occupants of public lands;
f) collectives or cooperatives of the above
beneficiaries; and
g) others directly working on the land.
(Par. 1, Sec. 22, RA 6657)
The children of landowners who
arequalified under Sec. 6 of this Act shall be
given preference in the distribution of the land of
their parents; And, further, that actual tenant-
tillers in the landholding shall be ejected or
removed therefrom. (Par. 2, Sec. 22, RA 6657)
Distribution Limit No qualified
beneficiary may own more than three (3)
influence, or fraud, an AGRICULTURAL
CONTRACT reduced in writing and
registered as hereinafter provided SHALL BE
CONCLUSIVE BETWEEN THE
CONTRACTING PARTIES, if not
DENOUNCED OR IMPUGNED WITHIN
THIRTY DAYS AFTER REGISTRATION. (Sec.
17, Republic Act No. 3844)
XII MODES OF TRANSFER OF THE LAND
TO THE TENANT OR BENEFICIARY
The landowner-agricultural lessor can
FREELY AND VOLUNTARILY TRANSFER the
landholding to the agricultural lessor by way
of:
1. Sale
2. Donation
3. Succession the agricultural lessee as
DEVISEE to the testators free portion in
the will.
However, the limitation imposed by law on
his right to acquire must be observed, i.e.
Legal prohibition on the acquisition of
property.
By operation of law, the agricultural-lessee
can acquire ownership of the subject
landholding by the exercise of the following
rights.
1. Right of Pre-emption; and
2. Right of Redemption
XIII CONSIDERATION FOR THE USE OF
VALUE OF THE LAND.
Consideration for the Lease of
Agricultural lands:
1. Not more than 25 per centum of the
SUCCESSION or TO THE
GOVERNMENT in accordance with
this Decree,the Code of Agrarian
Reform and other existing laws
and regulations.
NOTE: Sec. 6, EO
228 provides,"Ownership of lands
acquired by the farmer-beneficiary may be
transferred after full payment of
amortizations."
The EMANCIPATION
PATENT awarded to the TENANT-
BENEFICIARY CREATES
a VESTED RIGHT OF ABSOLUTE
OWNERSHIP in the landholding "a
right which has
become fixed and establishedand is
no longer open to doubt or
controversy." (Pagtalunan vs.
Tamayo, 183 SCRA 252)
The Mode of Transfer of Lands to
Tenant-Beneficiaries underPresidential
Decree No. 27 are the following:
1. OPERATION LAND TRANSFER
(OLT) under PD 27 and EO 228;
and
Operation Land Transfer is the
ORDERLY and SYSTEMATIC
TRANSFER of land from the
landowner to the tenant-farmer
under Presidential Decree No. 27.
2. DIRECT PAYMENT
SCHEME(DPS). The landowner
and the tenant-beneficiary can
AGREE on the DIRECT SALE terms
and conditions which are not onerous
to the tenant-beneficiary.
The value of the land shall be
equivalent to two and one half (2-1/2)
hectares of agricultural land. (Sec. 23, RA
6657)
Award Ceiling for Beneficiaries.
Beneficiaries shall be awarded an area NOT
EXCEEDING THREE (3) HECTARES which
may cover a CONTIGUOUS tract of land
or SEVERAL PARCELS of land cumulated up to
the prescribed award limits. (Sec. 25, RA
6657).
Payment by Beneficiaries. Lands
awarded pursuant to this Act shall be paid for the
beneficiaries to the LBP in thirty (30) annual
amortizations at six percent (6%) per
annum. The payments for the first three (3)
years after the award may be at reduced
amounts as established by the PARC: Provided,
That the first five (5) annual payments may not
be more than five percent (5%) of the value of
the annual gross production as established by
the DAR. Should the scheduled annual
payments after the fifth year exceed ten percent
(10%) of the annual gross production and the
failure to produce accordingly is not due to the
beneficiarys fault, the LBP may reduce the
interest rate or reduce the principal obligation to
make the repayment affordable.
The LBP shall have a lien by way of
mortgage on the land awarded to the beneficiary;
and this mortgage may be foreclosed by the LBP
for non-payment of an aggregate of three (3)
annual amortizations. The LBP shall advise the
DAR of such proceedings and the latter shall
subsequently award the forfeited landholding to
other qualified beneficiaries. A beneficiary
whose land, as provided herein, has been
foreclosed shall thereafter be permanently
disqualified from becoming a beneficiary under
this Act. (Sec. 26, RA 6657)
Transferability of Awarded Lands. - lands
acquired by beneficiaries under this Act may not
be sold, transferred or conveyed except through
average normal harvest during the three
agricultural years immediately preceding
the date the leasehold was established.
2. Deductible items:
a. Seedlings
b. Cost of Harvesting
c. Cost of Threshing
d. Cost of Loading
e. Cost of Hauling
f. Cost of Processing
3. If the land is cultivated for a period of less
than three years, the initial consideration is
based on the average normal
harvest during the preceding years when
the land was actually cultivated or on the
harvest of the first year if newly cultivated,
and the harvest is normal.
4. After the lapse of the first three normal
harvests, the final consideration shall be
based on the average normal harvest
during these three preceding agricultural
years.
5. In the absence of any agreement as to
the rental, the maximum allowed shall be
applied.
6. If Capital Improvement is introduced not
by the lessee to increase productivity, the
rentals shall be increased proportionally to
the consequent increase in production due
to the improvement.
7. In case of Disagreement the Court shall
determine the reasonable increase in
rental.
8. Capital improvement refers to any
permanent and tangible improvement on
times the AVERAGE HARVEST OF
THREE NORMALCROP YEARS
IMMEDIATELY PRECEDING THE
PROMULGATION OF THIS
DECREE.

hereditary succession, or to the government, or
to the LBP, or to other qualified beneficiaries for
a period of ten (10) years; Provided, however,
That the children or the spouse of the transferor
shall have a right to repurchase the land from the
government or LBP within the period of two (2)
years. Due notice of the availability of the land
shall be given by the LBP to he Barangay
Agrarian Reform Committee (BARC) of the
barangay where the land is situated. The
Provincial Agrarian Reform Coordinating
Committee (PARCCOM), as herein provided,
shall, in turn, be given due notice thereof by the
BARC.
If the land has not yet been fully paid by the
beneficiary, the rights to the land may be
transferred or conveyed, with prior approval of
the DAR, to any heir of the beneficiary or to any
other beneficiary who, as a condition for such
transfer or conveyance, shall cultivate the land
himself. Failing compliance herewith, the land
shall be transferred to the LBP which shall give
due notice of the availability of the land in the
manner specified in the immediately preceding
paragraph.
In the event of such transfer to the LBP, the
latter shall compensate the beneficiary in one
lump sum for the amounts the latter has already
paid, together with the value of improvements he
has made on the land. (Sec. 27, RA 6657)
The TITLES awarded to farmer-
beneficiaries under the CARP are the following:
1. Free Patent for Public, Alienable and
Disposable Lands;
2. CERTIFICATE OF LAND OWNERSHIP
AWARD (CLOA) for Resettlement Sites:
3. STEWARDSHIP CONTRACT for Lands
covered by INTEGRATED SOCIAL
the land that will result in increased
productivity. If done with the consent of the
lessee, then the lease rental shall be
increased proportionately.

FORESTRY PROGRAM (ISFP); and
4. CLOA for Private Agricultural Lands.
The MODES OF ACQUIRING LANDSfor
distribution under CARP:
a. COMPULSORY ACQUISITION (CA) (Sec.
16, RA 6657)
b. VOLUNTARY OFFER TO SELL (VOS) (Sec.
19, RA 6657)
c. VOLUNTARY LAND TRANSFER/DIRECT
PAYMENT SCHEME (VLT/DPS) (Sec.
20, RA 6657).
Factors/Criteria considered in determining just
compensation:
1. Cost of Acquisition of the land;
2. Current Value of like properties;
3. Nature of the land;
4. Actual use;
5. Income;
6. Sworn valuation by the landowner;
7. Tax Declaration;
8. Assessment made by government
assessors;
9. The social and economic benefits
contributed by the farmers, and
10. Non-payment of taxes or loans secured
from any government financing
institution on the land.
Basic Formula for the valuation of lands
covered by VOS and CA
LV = (CNI x 0.6) + (CS x 0.3) +
(MV x 0.1)
where:
LV = Land Value
CNI = Capitalized Net Income
CS = Comparable Sales
MV = Market Value per Tax Declaration
The above formula shall be used if all three
factors are present, relevant and applicable.
A.1. When the CS factor is not
present andCNI and MV are applicable,
the formula shall be:
LV = (CNI x 0.9) + (MV x 0.1)
A.2. When the CNI factor is not
present and CS and MV are applicable,
the formula shall be:
LV = (CS x 0.9) + (MV x 0.1)
A.3. When both CS and CNI are not present and
only MV is applicable, theformula shall be:
LV = (MV x 2)







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Preface
CARL (R.A. 6657, as amended) and Related Laws
History and Evolution of Major Agrarian Reform Laws
Issuances
Philippine Constitution
Laws, Statutes and Presidential Issuances
Supreme Court Decisions and Issuances
o Case Digests
o Decisions
Issuances
Court of Appeals Decisions
Implementing Rules and Regulations
Issuances from Other Government Agencies
Handbooks and Publications
Articles and Journals
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Lecture Materials
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JUST COMPENSATION IN AGRARIAN REFORM

1987 Constitution
Article XIII, Sec. 4
"The State shall, by law, undertake an agrarian reform program founded on the right of farmers and
regular farmworkers who are landless, to own directly or collectively the lands they till or, in the case of
other farmworkers, to receive a just share of the fruits thereof. To this end, the State shall encourage and
undertake the just distribution of all agricultural lands, subject to such priorities and reasonable retention
limits as the Congress may prescribe, taking into account ecological, developmental, or equity
considerations, and subject to the payment of just compensation. In determining retention limits, the State
shall respect the right of small landowners. The State shall further provide incentives for voluntary land-
sharing."
RA 6657, The CARP Law
15 June 1988
Coverage:
"The Comprehensive Agrarian Reform Law of 1988 shall cover, regardless of tenurial arrangement and
commodity produced, all public and private agricultural lands as provided in Proclamation No. 131 and
Executive Order No. 229, including other lands of the public domain suitable for agriculture." (Sec. 4)
RA 3844, Agricultural Land
Reform Code
8 August 1963
Abolished share tenancy relationship and provided for the expropriation of certain agricultural lands for
resale to qualified beneficiaries
Created Land Bank of the Philippines to finance the acquisition by the Government of landed estates for
division and resale to small landholders, as well as the purchase of the landholding by the agricultural
lessee from the landowner
PD 27, Operation Land Transfer
21 October 1972
Covers private agricultural lands primarily devoted to rice and corn
EO 228
17 July 1987
Declared qualified farmer beneficiaries as full owners of the land as of 21 October 1972
Provides for the valuation mechanism for lands acquired pursuant to PD 27
FORMULA UNDER EO 228
LV = (2.5 x AGP x P35/31) x A
Where:
LV = Land Value
AGP = Average Gross Production/hectare
P35/31 = Government Support Price for one (1) cavan of palay/corn in 1972
A = Total area of the land
Proclamation No. 131
22 July 1987
Instituted the CARP
EO 229
22 July 1987
Provides the mechanism for the implementation of the CARP
Association of Small Landowners in the Philippines vs. Secretary of Agrarian Reform(G.R. No. 78742, En Banc,
14 July 1989)
"WHEREFORE, the Court holds as follows:
1. R.A. No. 6657, P.D. No. 27, Proc. No. 131, and E.O. Nos. 228 and 229 are SUSTAINED against all
the constitutional objections raised in the herein petitions.
xxx xxx xxx"
1987 Constitution
Article XIII, Sec. 4
"The State shall, by law, undertake an agrarian reform program founded on the right of farmers and regular
farmworkers who are landless, to own directly or collectively the lands they till or, in the case of other
farmworkers, to receive a just share of the fruits thereof. To this end, the State shall encourage and undertake the
just distribution of all agricultural lands, subject to such priorities and reasonable retention limits as the Congress
may prescribe, taking into account ecological, developmental, or equity considerations, and subject to the
payment of just compensation. In determining retention limits, the State shall respect the right of small
landowners. The State shall further provide incentives for voluntary land-sharing."
Stakeholders in Agrarian Reform
Farmer-Beneficiaries
Landowners
Government
Just Compensation
The just and complete equivalent of the loss which the owner of the thing expropriated has to suffer by reason of the
expropriation.
The compensation given to the owner is just compensation if he receives for his property a sum equivalent to its market
value.
City of Manila vs. Estrada
25 Phil 208 (1913)
Market Value
It is the price fixed by the buyer and the seller in the open market in the usual and ordinary course of legal trade and
competition; the price and value of the article established or shown by sale, public or private, in the ordinary course of
business; the fair value of property as between one who desires to purchase and one who desires to sell.
City of Manila vs. Estrada
25 Phil 208 (1913)
1987 Constitution
Article III, Sec. 9
"Private property shall not be taken for public use without just compensation."
1987 Constitution
Article XIII, Sec. 4
"The State shall, by law, undertake an agrarian reform program founded on the right of farmers and regular farmworkers,
who are landless, to own directly and indirectly the lands they till or, in the case of other farmworkers, to receive a just
share of the fruits thereof. To this end, the State shall encourage and undertake the just distribution of all agricultural lands,
subject to such priorities and reasonable retention limits as the Congress may prescribe, taking into account ecological,
developmental, or equity considerations, and subject to the payment of just compensation. In determining retention
limits, the State shall respect the rights of small landowners. The State shall further provide incentives for voluntary land-
sharing.
1987 Constitution
Article III Bill of Rights
It is a guarantee that there are certain areas of a person's life, liberty, and property which governmental power may not
touch.
Article XIII Social Justice
The goal of social justice is closer regulation of the acquisition, ownership, use, and disposition of property in order to
achieve a more equitable distribution of wealth and political power.
Fr. Joaquin G. Bernas, S.J.
The 1987 Philippine Constitution
A Reviewer-Primer

"In trying to determine just compensation for purposes of agrarian reform, we must remember that we have to
look at this in the context of the Article where it is. It is in the Article on Social Justice, and the thrust of this
Article is precisely to make it easier for the disadvantaged to be able to obtain land."
- Fr. Joaquin G. Bernas, SJ

"When pursuant to an agrarian reform mandate that is intended to reduce inequalities, as social justice
commands, land is taken for redistribution, is the action taken by the state pure eminent domain or is it not
eminent domain mixed with the exercise of police power? But it is established jurisprudence that loss incurred due
to the state's exercise of police power is not compensable. It would seem therefore that compensation in
expropriation for land reform should be approached differently than under the Bill of Rights when
property is taken for traditional purposes."
- Fr. Joaquin G. Bernas, SJ
Association of Small Landowners in the Philippines vs. Secretary of Agrarian Reform(G.R. No. 78742, En Banc,
14 July 1989)
"What we deal with here is a revolutionary kind of expropriation.
The expropriation before us affects all private agricultural lands whenever found and of whatever kind as
long as they are in excess of the maximum retention limits allowed their owners. This kind of expropriation is
intended for the benefit not only of a particular community or of a small segment of the population but of the entire
Filipino nation, from all levels of our society, from the impoverished farmer to the land-glutted owner. . ."
- J. Isagani Cruz
Sec. 17, RA 6657
"In determining just compensation, the cost of acquisition of the land, the value of the standing crop, the current
value of like properties, its nature, actual use and income, the sworn valuation by the owner, the tax declarations,
the assessment made by government assessors, and seventy percent (70%) of the zonal valuation of the Bureau
of Internal Revenue (BIR), translated into a basic formula by the DAR shall be considered, subject to the final
decision of the proper court. The social and economic benefits contributed by the farmers and the farmworkers
and by the Government to the property as well as the nonpayment of taxes or loans secured from any
government financing institution on the said land shall be considered as additional factors to determine its
valuation."
Sec. 49, RA 6657
"The PARC and the DAR shall have the power to issue rules and regulations, whether substantive or
procedural, to carry out the objects and purposes of this Act. Said rules shall take effect ten (10) days after
publication in two (2) national newspapers of general circulation."
DAR AO No. 5, Series of 1998
"There shall be one basic formula for the valuation of lands covered by VOS or CA:
LV = (CNI x 0.6) + (CS x 0.3) + (MV x 0.1)

Where:

LV = Land Value
CNI = Capitalized Net Income
CS = Comparable Sales
MV = Market Value"
LandBank vs. Banal
(G.R. No. 143276, 3rd Division, 20 July 2004)
"(I)n determining the valuation of the subject property, the trial court shall consider the factors provided under
Section 17 of RA 6657, as amended. . . . The formula prescribed by the DAR in Administrative Order No. 6,
Series of 1992, as amended by DAR Administrative Order No. 11, Series of 1994, shall be used in the valuation
of land."
- J. Sandoval-Gutierez
LandBank vs. Celada
(G.R. No. 164876, 1st Division, 23 January 2006)
"DAR AO No. 5, s. of 1998 precisely "filled in the details" of Section 17, RA 6657 by providing a basic formula by
which the factors mentioned therein may be taken into account."
"SAC was at no liberty to disregard the formula which was devised to implement the said provision."
- J. Ynares-Santiago
LandBank vs. Lim and Cabochan
(G.R. No. 171941, En Banc, 2 August 2007)
"In Land Bank of the Philippines v. Spouses Banal, this Court underscored the mandatory nature of Section 17
of RA 6657 and DAR AO 6-92, as amended by DAR AO 11-94.
xxx xxx xxx"
"And in LBP v. Celada, this Court set aside the valuation fixed by the RTC of Tagbilaran, which was based solely
on the valuation of neighboring properties, because it did not apply the DAR valuation formula.
xxx xxx xxx"
"Consequently, as the amount of P2,232,868 adopted by the RTC in its December 21, 2001 Order was not
based on any of the mandatory formulas prescribed in DAR AO 6-92, as amended by DAR AO 11-94, the
Court of Appeals erred when it affirmed the valuation adopted by the RTC."
- J. Carpio Morales
Some Cases Reiterating the Doctrine in Banal, Celada and Lim that Adherence to the Formula Prescribed by
the DAR is Mandatory
LBP v. Wycoco, (G.R. No. 140160, 13 January 2004)
Sps. Zoleta, et al. v. Hon. Andres Reyes, et al., (G.R. No. 169054, 31 August 2003)
De Castro, et al. v. LBP, (G.R. No. 168026, 03 August 2005)
Meneses v. DAR Secretary, et al., (G. R. No. 156304, 23 October 2006)
LBP vs. Heirs of Eleuterio Cruz, (G.R. No. 175175, September 29, 2008)
Land Bank of the Philippines v. Dumlao, (G.R. No. 167809, November 27, 2008)
Allied Bank Corporation v. Land Bank of the Philippines, (G.R. No. 175422, March 13, 2009)
Land Bank of the Philippines v. Heirs of Honorato De Leon, (G.R. No. 164025, May 8, 2009)
LBP v. Belista, (G.R. No. 164631, 26 June 2009)
LBP v. Kumassie Plantation Co., (G.R. No. 177404, December 4, 2009)
LBP v. Alpasan, Jr., (G.R. No. 188221, 03 February 2010)
LBP v. Escandor, (G. R. No. 171685, 11 October 2010)
LBP v. Barrido, (G.R. No. 183688, August 18, 2010)
Case where the Supreme Court departed from the doctrine
APO Fruits Corporation and HIJ O Plantation, Inc. vs. Court of Appeals, (G.R. No. 164195, February 6,
2007)
More Supreme Court cases since 2004 were decided in accordance with the doctrine espoused in Banal,
Celada and Lim Cabochan
Only case decided by the Supreme Court En Bancinvolving the issue of how just compensation in land
reform is to be computed is LBP vs. Lim and Cabochan
Date of Taking
(Section 2, Rule 67 of the Rules of Court)
General Rule in Expropriation Proceedings:
- Filing of the complaint
- Due notice to owner
- Deposit of Compensation
Taking Under RA 6657
(Secs. 16 (e) & 24, par. 2, RA 6657, as amended)
Payment to LO
Deposit, in case of rejection
Issuance of title in the name of RP
Taking Under PD 27
October 21, 1972
- Locsin vs. Valenzuela, 194 SCRA 194;
- Ass'n. of Small Landowners vs. Sec. of Agrarian Reform, G.R. Nos. 78742, 79310, 79744 & 79777,
14 July 1989;
- LBP vs. David C. Naval, et al., G.R. No. 122231, 27 November 1995;
- NPC vs. Chiong, G.R. No. 152436, 20 June 2003;
- Gabatin vs. LBP, G.R. No. 148223, 25 November 2004.
Formula upheld where taking is October 21, 1972 is the formula under PD 27/EO 228.
LV = (2.5 x AGP x P35/31) x A
Variance in the Reckoning of Date of Taking
Upon payment of just compensation judicially determined
- OP, et al. vs. CA, G.R. No. 131216, 19 July 2001
- LBP vs. Estanislao, G.R. No. 166777, 10 July 2007
Date of issuance of EPs
- LBP vs. Domingo, G.R. No. 168533, 4 February 2008;
- LBP vs. Dumlao, G.R. No. 167809, 27 November 2008;
- DAR vs. Tiongson, G.R. No. 171674, 4 August 2009.
Effect of Change in Date of Taking
Formula under RA 6657 is to be used, resulting in higher valuation. Rationale is because the agrarian reform process is not
yet complete when RA 6657 took effect on 15 June 1988.
LV = (CNI x .60) + (CS x .30) + (MV x .10)
Reason for Divergent PD 27 Rulings on the Date of Taking
Courts have recognized that the determination of the value of the land as of October 21, 1972 will result in
a low valuation and fixing the date of taking on a later date, and in accordance with RA 6657, will increase
the valuation.
Relevance of PD 27 Jurisprudence Today
RA 9700 (July 1, 2009) rendered the issue on date of taking for PD 27-acquired lands moot and
academic.
Section 5 of RA 9700 all previously-acquired lands subject to challenge should be finally resolved in
accordance with Section 17 of RA 6657, as amended.
DAR AO No. 1, series of 2010 provides that the reckoning date of the AGP and SP inputs needed in
the computation shall be June 30, 2009; provides the legal formula in the computation:
LV = (CNI x .60) + (CS x .30) + (MV x .10)
or
LV = (CNI x .90) + (MV x .10)
Amount to be Deposited
Section 16 (a), (b), (d), & (e) of RA 6657
"(a) . . . Said notice shall contain the offer of the DAR to pay a corresponding value in accordance with the
valuation set forth in Sections 17, 18, and other pertinent provisions hereof.
(b) Within thirty (30) days from the date of receipt of written notice by personal delivery or registered mail, the
landowners, his administrator, or representative shall inform the DAR of his acceptance or rejection of the offer."
(c) If the landowner accepts the offer of the DAR, the LBP shall pay the landowner the purchase price of the
land within thirty (30) days after he executes and delivers a deed of transfer. . .
(e) "Upon receipt by the landowner of the corresponding payment or in case of rejection or no response
from the landowner, upon the deposit with an accessible bankdesignated by the DAR of the
compensation in cash or in LBP bonds in accordance with this Act, the DAR shall take immediate
possession of the land and shall request the proper Register of Deeds to issue a Transfer Certificate of
Title (TCT) in the name of the Republic of the Philippines.The DAR shall thereafter proceed with the
redistribution of the land to qualified beneficiaries."
LBP v. Arieta Tan
(G.R. No. 161834, August 23, 2010)
"The amount of 'offer' which the DAR gives to the landowner as compensation for his land, as mentioned in
Section 16 (b) and (c), is based on the initial valuation by the LBP. This then is the amount which may be
accepted or rejected by the landowner under the procedure established in Section 16. Perforce, such initial
valuation by the LBP also becomes the basis of the deposit of provisional compensation pending final
determination of just compensation, in accordance with sub-paragraph (e)."
Amount that can be Withdrawn
LBP v. J osefina Lubrica,
(G.R. No. 177190, February 23, 2011)
"Clearly, therefore, it is the initial valuation made by the DAR and LBP that is contained in the letter-offer to the
landowner under Sec. 16 (e), said valuation of which must be deposited and released to the landowner
prior to taking possession of the property."
Sec. 18, RA 6657
"The LBP shall compensate the landowner in such amounts as may be agreed upon by the landowner and the
DAR and the LBP, in accordance with the criteria provided for in Sections 16 and 17, and other pertinent
provisions hereof, or as may be finally determined by the court, as the just compensation for the land."
Sec. 16, RA 6657
"Any party who disagrees with the decision may bring the matter to the court of proper jurisdiction for
final determination of just compensation."
Sec. 57, RA 6657
"The Special Agrarian Courts shall have original and exclusive jurisdiction over all petitions for the
determination of just compensation to landowners, and the prosecution of all criminal offenses under this Act. The
Rules of Court shall apply to all proceedings before the Special Agrarian Courts, unless modified by this Act."
DAR Adjudication Board (DARAB)
"Section 16. Procedure for Acquisition of Private Lands.
xxx xxx xxx
(d) In case of rejection or failure to reply, the DAR shall conduct summary administrative proceedings to
determine the compensation for the land requiring the landowner, the LBP and other interested parties to submit
evidence as to the just compensation for the land, within fifteen (15) days from the receipt of the notice. . . ." (RA
6657)
Sec. 50, RA 6657

Quasi-Judicial Power of the DAR. The DAR is hereby vested with primary jurisdiction to determine and
adjudicate agrarian reform matters and shall have exclusive original jurisdiction over all matters involving the
implementation of agrarian reform, except those falling under the exclusive jurisdiction of the Department of
Agriculture (DA) and the Department of Environment and Natural Resources (DENR)


DARAB Rules of Procedures
1. 2009
2. 2003
3. 1994
DARAB and SAC's Jurisdiction
Philippine Veterans Bank v. CA
(G.R. No. 132767. January 18, 2000)
No contradiction in the jurisdiction of DARAB and SAC.
Proceedings before the DARAB is administrative while the proceedings before SAC is judicial.
LBP vs. Wycoco
(G.R. No. 140160, 13 January 2004)
Direct resort to SAC is valid
SAC is not an appellate court of DARAB
Summary administrative proceedings before the DARAB is not necessary prior to filing before the SAC
LBP vs. Belista
(G.R. No. 164631, 26 June 2009)
Party need not appeal the Adjudicator's decision to the DARAB before it can file a petition for determination of just
compensation before the SAC.
Land Bank of the Philippines v. Celada
(G.R. No. 164876, 23 January 2006)
Apo Fruits and Hijo Plantation, I nc. vs. CA
(G.R. No. 164195, 6 February 2007)
Notwithstanding the pendency of a just compensation case before the DARAB, a party may file a petition before the SAC.
Time to File Original Action Before the SAC
Philippine Veterans Bank v. CA, (G.R. No. 132767, January 18, 2000)
LBP vs. Raymunda Martinez, (G.R. No. 169008, July 31, 2008)
Although the proceedings before the SAC is not appellate in nature the petition for the fixing of just compensation should
be filed within 15 days period from receipt of the adverse DARAB decision.
Sec. 60, RA 6657
"An appeal may be taken from the decision of the Special Agrarian Courts by filing a petition for review with
the Court of Appeals within fifteen (15) days from receipt of notice of the decision; otherwise, the decision
shall become final.
An appeal from the decision of the Court of Appeals, or from any order, ruling or decision of the DAR, as the case
may be, shall beby a petition for review with the Supreme Court within a non-extendible period of fifteen
(15) days from receipt of a copy of said decision."
LBP vs. Arlene de Leon
(G.R. No. 143275, 20 March 2003)
"We ruled that the Rules of Court does not categorically prescribe ordinary appeal as the exclusive mode of
appeal from decisions of Special Agrarian Courts. The reference by Section 61 to the Rules of Court in fact even
supports the mode of a petition for review as the appropriate way to appeal decisions of the Special Agrarian
Courts. . .
"WHEREFORE, the motion for reconsideration dated October 16, 2002 and the supplement to the motion for
reconsideration dated November 11, 2002 are PARTIALLY GRANTED. While we clarify that the Decision of this
Court dated September 10, 2002 stands, our ruling therein that a petition for review is the correct mode of appeal
from decisions of Special Agrarian Courts shall apply only to cases appealed after the finality of this Resolution."
ARF is solely answerable for just compensation to landowner
Sec. 63, RA 6657, as amended by RA 9700
". . . all just compensation payments to landowners, including execution of
judgments therefor, shall only be sourced from the Agrarian Reform Fund;"
Interest on Just Compensation
1. When there is no delay in payment.
2. When there is a delay in payment.
When there is no delay
Cash portion prevailing savings rate
Bond portion interest rate aligned with the 91-day TB rates(Section 18, RA 6657, as amended)
When there is delay
Art. 2209, Civil Code
CB Circular 416
Eastern Shipping vs. CA, (G.R. No. 168453, 13 March 2009)
Apo-Hijo vs. LBP
(G.R. No. 164195, 12 April 2011)
Forbearance of money
12% interest
Peculiar Circumstances in Apo-Hijo vs. LBP
Market value upheld over value determined under DAR valuation guidelines.
SC decided case on the merits when issue on appeal is procedural.
2nd MR of APO elevated to the SC En Banc and given due course inspite of Entry of Judgment.
3rd MR of APO given due course without 2/3 vote of the Justices pursuant to SC Internal Rules of
Procedure.
Payment of just compensation classified as forbearance of money to justify 12% interest.



HELP CENTER
How to Use the ERC Legal Information Archive
CONTACT INFORMATION
Department of Agrarian Reform
Elliptical Road, Diliman
Quezon City, Philippines
Tel. No.: (632) 928-7031 to 39
Copyright Information
All material contained in this site is copyrighted by the Department of Agrarian Reform unless otherwise specified. For the purposes of this demo, information are
intended to show a representative example of a live site. All images and materials are the copyright of their respective owners.

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