Petitioner
Land Bank of the Philippines
Respondent
Espedito Q. Escaro
Citation
G.R. No. 204526
Court
Supreme Court
Division
Third Division
Ponente
Hernando, J.
Decided
February 10, 2021

Summary

This case involves a dispute over just compensation for land expropriated under the Comprehensive Agrarian Reform Program. The Supreme Court abandoned its previous rulings requiring landowners to file actions for just compensation within 15 days of receiving DARAB decisions, declaring such requirement void for undermining the original and exclusive jurisdiction of Regional Trial Courts sitting as Special Agrarian Courts. The Court established that determination of just compensation is a judicial function that cannot be limited by administrative rules. The proper prescriptive period is 10 years under the Civil Code, tolled by administrative proceedings. This landmark decision clarifies that RTC-SACs have original, not appellate, jurisdiction over just compensation cases, and that DARAB cannot promulgate rules that effectively bar courts from exercising their constitutional mandate to determine just compensation.

Statutes applied

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By Intellegal Editorial Board · February 10, 2021

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