Land Bank of the Philippines v. Sps.

Vicente and Leonidas Arenas-Banal

G.R. No. 143276. July 20, 2004
Third Division

Sandoval-Gutierrezz, J.:

DOCTRINE: Courts are not authorized to take judicial notice of the contents of the records of
other cases even when said cases have been tried or are pending in the same court or before the
same judge. They may only do so in the absence of objection and with the knowledge of the
opposing party.

FACTS:

Spouse Banal are the registered owners of an agricultural land. A portion thereof was
compulsorily acquired by Department of Agriculture (DAR) pursuant to the Comprehensive
Agrarian Reform Law (CARL).

The spouses rejected the valuation of Land Bank, hence a summary administrative
proceeding was conducted before the Provincial Agrarian Reform Adjudicator (PARAD) to
determine the value of the land. PARAD affirmed Land Bank’s valuation.

Dissatisfied, spouses Banal filed with the Regional Trial Court (RTC) a Petition for
Determination of Just Compensation. In determining the valuation of the land, RTC based the
same on the facts established in another case pending before it without conducting a hearing and
without the knowledge or consent of the parties.

ISSUE:
Can the court take judicial notice of the facts established in another case pending before it?

HELD:
 No. Well-settled is the rule that courts are not authorized to take judicial notice of the
contents of the records of other cases even when said cases have been tried or are pending in the
same court or before the same judge. They may only do so in the absence of objection and with
the knowledge of the opposing party, which are not obtaining here.

Furthermore, as earlier stated, the Rules of Court shall apply to all proceedings before the Special
Agrarian Courts. In this regard, Section 3, Rule 129 of the Revised Rules on Evidence is explicit
on the necessity of a hearing before a court takes judicial notice of a certain matter.