9/16/25, 10:15 PM Land Bank of the Philippines vs.
Spouses Chu
Title
Land Bank of the Philippines vs. Spouses Chu
Case Decision Date
G.R. No. 192345 Mar 29, 2017
Land valuation dispute under agrarian reform laws; CA erred in disregarding RA 6657
guidelines, remanded to RTC for proper computation of just compensation.
Jur.ph - Case Digest (G.R. No. 192345)
Expanded Legal Reasoning Model
Facts:
Background of the Case
The Petitioner, Land Bank of the Philippines (LBP), assailed lower court decisions
regarding the valuation of two parcels of agricultural land.
The Respondents, spouses Esteban and Cresencia Chu, are the registered owners of
the disputed properties located in San Antonio, Pilar, Sorsogon.
The properties were acquired by the government under its agrarian reform
program, with one parcel falling under Presidential Decree No. 27 (PD 27) and the
other under Republic Act No. 6657 (RA 6657).
Description of the Properties
PD 27–Acquired Land
Covered by Transfer Certificate of Title Nos. T-27060 and T-27062.
Total area stated is approximately 14.9493 hectares.
Initially, LBP valued this parcel at P177,657.98 using the formula: Land Value =
AGP × ASP × 2.5, where ASP was erroneously taken as P350 instead of the
mandated P35.
RA 6657–Acquired Property
Consists of a parcel with an area of 7.7118 hectares, covered by a separate portion
of TCT No. T-27060.
LBP’s initial valuation of this property was P263,928.57.
Respondents rejected LBP’s valuation, prompting summary administrative
proceedings.
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9/16/25, 10:15 PM Land Bank of the Philippines vs. Spouses Chu
Administrative and Lower Court Proceedings
Administrative Proceedings
The Provincial Agrarian Reform Adjudication Board (PARAD) conducted
summary administrative proceedings under Land Valuation Cases Nos. LV-30-
'03 (RA 6657–acquired) and LV-48-'03 (PD 27–acquired).
The PARAD recomputed the values:
RA 6657–acquired property at P1,542,360.00 (at a rate of P200,000.00 per
hectare), factoring in comparable sales and a Municipal Resolution declaring
the area as industrial.
ii. PD 27–acquired land at P983,663.94 using the formula based on an Average Gross
Production and Actual Support Price.
LBP’s Motion for Reconsideration before PARAD was denied.
Regional Trial Court (RTC) Proceedings
LBP filed a Petition for Determination of Just Compensation.
The RTC, sitting as a Special Agrarian Court, rendered a decision setting just
compensation at:
P2,313,478.00 for the RA 6657–acquired property.
ii. P1,155,173.00 for the portion acquired under PD 27, though the computation involved
adding a value of P100,000.00 per hectare based on the lands’ “potentials.”
The RTC’s decision was based on both the factors considered by PARAD and additional
evidence regarding the intended economic development of the area.
Court of Appeals (CA) Ruling
The CA modified the RTC decision by:
Upholding the LBP’s valuation for the PD 27–acquired land at P177,657.98 but
awarding 12% per annum legal interest.
ii. Affirming that for the RA 6657–acquired property, the proper valuation must adhere to
Section 17 of RA 6657 and the DAR Administrative Order No. 5, series of 1998, thus fixing its
price at P200,000.00 per hectare.
LBP’s Motion for Reconsideration before the CA was denied, which eventually led to
this Petition for Review on Certiorari.
Issues:
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9/16/25, 10:15 PM Land Bank of the Philippines vs. Spouses Chu
Applicability and Proper Computation of Valuation Factors
Whether the valuation for the RA 6657–acquired property was improperly
computed by disregarding the mandatory valuation factors under Section 17 of RA
6657 and relevant DAR administrative orders.
Remand for Re-computation of the PD 27–Acquired Land
Whether the CA erred in refusing to remand the case to the RTC for a re-
computation of the PD 27–acquired land’s valuation pursuant to Section 17 of RA
6657, as amended.
Issue on the Award and Computation of Interest
Whether the imposition of legal interest at 12% per annum on the PD 27–acquired
land by the CA is proper given the statutory framework and related jurisprudence.
Ruling:
(Subscriber-Only)
Ratio:
(Subscriber-Only)
Doctrine:
(Subscriber-Only)
Note: AI summaries may not capture all details. Please refer to full text for complete accuracy.
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