THIRD DIVISION
G.R. No. 208004, July 30, 2018
LAND BANK OF THE PHILIPPINES, Petitioner, v. PRADO VERDE CORPORATION, Respondent
[G.R. No. 208112]
PRADO VERDE CORPORATION, Petitioner, v. LAND BANK OF THE PHILIPPINES, Respondent
[G.R. No. 210243]
LAND BANK OF THE PHILIPPINES, Petitioner, v. PRADO VERDE CORPORATION, Respondent.
D E C I S I O N
GESMUNDO, J.:
The instant petitions are rooted from the March 21, 2012 Decision1 and June 11, 2012 Resolution2 of the Regional Trial Court of Legazpi City, Branch 3 (RTC), in Agrarian Case No. 08-04, a case for just compensation filed by Prado Verde Corporation (Prado), formerly United Plaza Properties, Inc., against Land Bank of the Philippines (Land Bank) whereby the trial court directed Land Bank to pay Prado the amount of P294,495.20 as just compensation, an amount which was higher than Land Bank's revalued amount of P214,026.38.
After both parties' respective motions for reconsideration were denied, each party filed its separate petition for review before the Court of Appeals (CA). Prado's petition was raffled to the Sixth Division and was docketed as CA-G.R. SP No. 125525, while Land Bank's petition was raffled to the First Division, docketed as CA-G.R. SP No. 125471.
Learning of the two petitions, both parties moved for consolidation in CA-G.R. SP No. 125471, said case having the lower docket number. However, pending resolution of the motion, the CA Sixth Division rendered a Decision3 on January 31, 2013, and later a Resolution4 on July 8, 2013, affirming the decision of the RTC and denying the parties' motions for reconsideration, respectively. Thus, Land Bank and Prado filed their separate petitions for review before the Court, docketed as G.R. No. 208004 and G.R. No. 208112. Both petitions were later consolidated.
Subsequently, the CA First Division denied the motion for consolidation, the same having been mooted by the January 31, 2013 Decision of the Sixth Division. Thus, it later rendered a Resolution5 on December 4, 2013 dismissing Land Bank's petition for lack of merit. Hence, Land Bank filed a petition for review before the Court, docketed as G.R. No. 210243.
Since all three petitions are not simply intertwined, but involve the very same parties, facts and issues, consolidation is therefore in order.
Antecedents
Prado was the owner of an agricultural land known as Lot 5834-A, covered by Transfer Certificate of Title (TCT) No. 4141 issued in the name of Legazpi Oil Company, Inc. (Legazpi Oil), from which Prado bought said property in 1979. The property remained registered in the name of Legazpi Oil and the sale was not annotated on the TCT. However, on July 9, 1980, the deed of absolute sale in favor of United Plaza Properties, Inc. was presented for registration and was duly registered before the Registry of Deeds of Legazpi. The said property was placed within the coverage of the Agrarian Reform Program under Presidential Decree (P.D.) No. 27 and a portion thereof, with an area of 2.4975 hectares, was placed within the coverage of Operation Land Transfer on December 4, 1995. As of August 2010, the landowner of the agricultural property had not yet been compensated. Prado received the claims folder from the Department of Agrarian Reform (DAR) on January 24, 1996.
Meanwhile, on April 21, 1988 and pursuant to Emancipation Patent issued by DAR, the Registry of Deeds entered in its registry TCT Nos. 58 and 59 over portions of Lot 5834-A, which portions were then known as Lot No. 5834-A-1, issued in the name of farmer-beneficiary Salustiano Arcinue and Lot No. 5834-2 issued in the name of farmer-beneficiary Agapito Azupardo, respectively. Thus, TCT No. 4141 was partially cancelled with regard to the 2.4975 hectare portion, which portion was previously classified as riceland, of Lot No. 5834-A.
On January 1996, Land Bank initially valued the acquired property in the amount of P38,885.04 pursuant to P.D. No. 27. Then, a revaluation was made and the compensation was pegged in the amount of P59,457.05 which amount, for unknown reason, was not received by the landowner. Thus, Prado filed an agrarian suit before the RTC.
During the pendency of the case, Land Bank further revalued the property using the reckoning dates of production data and values pursuant to Administrative Order (A.O.) No. 1, series of 2010, which the DAR issued under Republic Act (R.A.) No. 9700, and the two-factor formula prescribed therein [(LV = (CNI x 0.90) + (MV x 0.10)], thus arriving at the amount of P214,026.38. However, Prado rejected the revalued compensation.
On March 21,2012, the RTC, acting as a Special Agrarian Court (SAC), rendered a Decision6 fixing the amount of just compensation at P294,495.20. The trial court held that just compensation of the subject properties should be computed pursuant to A.O. No. 5, Series of 1998, as amended by A.O. No. 2, Series of 2009 and A.O. No. 1, Series of 2010, which reckoned the determination of just compensation based on the condition of the property prevailing within the 12-month period preceding June 30, 2009, the presumptive date of taking.7 The computation was as follows:
LV = (CNI x 0.60) + (CS x 0.30) + (MV x 0.10)Unsatisfied, both parties moved for reconsideration. Prado claimed that the valuation of the property should be based on the zonal value of the residential lots within the vicinity where the property is located, while Land Bank argued that its revaluation should be upheld.
Where: LV = Land Value
CNI = Capitalized Net Income which refers to the gross sales
(AGP x SP) with assumed net income rate of 20%
Capitalized at 0.12
CS = Comparable Sales (based on fair market value equivalent to 70% of BIR Zonal Value)
MV = Market Value per Tax Declaration
CNI = (AGP x SP) x 0.20
0.12
= (5,900 x P9.00) x 0.20
0.12
= P88,500.00
CS = P20.00 zonal value/square meter x 10,000 sq. m.
= P200,000.00
MV = P30,100.00 x 100% x 1.60
= P48,160.00
LV = (CNI x 0.60) + (CS X 0.30) + (MV x 0.10)
= (88,500.00 x 0.60) + (200,000.00 x 0.30) + (48,160.00 x 0.10)
= 53,100.00 + 60,000.00 + 4,816.00
= P117,916.00 per hectare
Total LV = LV x area acquired
= 117,916.00 x 2.4975 hectares
= P294.495.20
Indeed, the Court a quo's findings closely conformed to the factors listed in Section 17 of RA No. 6657 especially the factors of actual use and income of the subject properties. It has been consistently ruled that the ascertainment of just compensation by the RTC as SAC on the basis of the landholding's nature, location, market value, assessor's value and the volume and the value of produce is valid and accords with Section 17, supra. In the absence of proof to show that the Court a quo, acting as Special Agrarian Court, committed grievous error in the appreciation and weighing of the evidence, We respect its findings. Accordingly, the determined amount by the Court [a quo], in eminent domain terms, is the "real, substantial, full and ample" compensation the government must pay to be "just" to the landowner, herein petitioner.13 (citations omitted)Unsatisfied with the decision, Prado and Land Bank filed their respective motions for reconsideration. However, both motions were denied. Thus, they sought relief before the Court.
As the law now stands, it is clear that the RTC, acting as Special Agrarian Court, is duty-bound to take into consideration the factors fixed by Section 17 of Republic Act (RA) No. 6657, as amended, and apply the basic formula prescribed and laid down in the pertinent administrative regulations.Undaunted, Land Bank proceeded before the Court via a petition for review questioning the above disposition.
After a judicious evaluation of the petition, as well as the evidence on record, We find and so hold that the Petitioner failed to sufficiently show that the RTC ignored, misconstrued, or misapplied any cogent facts and circumstances which, if considered, would warrant a modification or reversal of the outcome of the case. On the contrary, it conformed with the factors listed in Section 17 of the above law in determining just compensation. In the absence of proof to show that it committed grievous error in its dispositions, We have to respect its findings.15
I.
WHETHER OR NOT THE COURT OF APPEALS ERRED IN AFFIRMING THE SAC'S DETERMINATION OF JUST COMPENSATION.II.
WHETHER OR NOT THE COURT OF APPEALS ERRED IN AFFIRMING THE JUDGMENT OF THE SAC ORDERING THE IMMEDIATE PAYMENT OF ITS ADJUDGED JUST COMPENSATION, WITH INTEREST AT 12% IF UNHEEDED WITHIN 30 DAYS FROM NOTICE, EVEN IF THE ORDER IS NOT YET FINAL AND EXECUTORY.
For the guidance of the bench, the bar, and the public, we reiterate the rule: Out of regard for the DAR's expertise as the concerned implementing agency, courts should henceforth consider the factors stated in Section 17 of RA 6657, as amended, as translated into the applicable DAR formulas in their determination of just compensation for the properties covered by the said law. 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.19 (emphasis supplied)Parties' respective arguments before the Court
The determination of just compensation is a judicial function. The "justness" of the enumeration of valuation factors in Section 17, the "justness" of using a basic formula, and the "justness" of the components (and their weights) that flow into the basic formula, are all matters for the courts to decide. As stressed by Celada, however, until Section 17 or the basic formulas are declared invalid in a proper case, they enjoy the presumption of constitutionality. This is more so now, with Congress, through RA 9700, expressly providing for the mandatory consideration of the DAR basic formula. In the meantime, Yatco, akin to a legal safety net, has tempered the application of the basic formula by providing for deviation, where supported by the facts and reasoned elaboration.34Undoubtedly, the courts are not at liberty to deviate from the DAR basic formula, unless such deviations are amply supported by facts and reasoned justification.
Section 7. Section 17 of Republic Act No. 6657, as amended, is hereby further amended to read as follows:The factors to be considered in fixing the amount of just compensation were translated into a basic formula. A.O. No. 5, series of 1998, A.O. No. 2, series of 2009 and even the most recent DAR A.O. No. 7, series of 2011 all provide that the basic formula shall be:SECTION 17. Determination of Just Compensation. - 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.
LV = (CNI x 0.6) + (CS x 0.3) + (MV x 0.1)1.1 If the three factors are present
Where: LV = Land Value
CNI35 = Capitalized Net Income (based on land use and productivity)
CS36 = Comparable Sales (based on fair market value Equivalent to 70% of BIR zonal value)
MV37 = Market Value per Tax Declaration (based on Government assessment)
II. COVERAGEHere, the subject properties are rice lands placed under the coverage of and acquired pursuant to the Operation Land Transfer program under P.D. No. 27.38 Thus, the SAC and the Land Bank correctly relied on A.O. No. 1, series of 2010 in governing the valuation of the subject 2.4975-hectare rice land.
- Lands already distributed by the DAR to the farmer-beneficiaries where documentation and/or valuation are/is not yet complete (Distributed But Not Yet Documented [DNYD] claims).
- PD 27/EO 228 claims with the Land Bank of the Philippines where:
- The DAR valuation is rejected by the landowner OR
- The DAR valuation is undergoing summary proceeding with the DARAB or just compensation case with the Court OR
- The landowner accepts the original valuation under protest or without prejudice to the determination of just compensation OR
- The landowner refuses or fails to submit or comply with the pre-payment/documentary requirements under PD 27/EO 228 formula despite receipt of notice of demand.
- Rice and Corn lands under PD 27 falling under Phase 1 of RA 9700.
Where:On the other hand, item IV. 2 of A.O. No. 1 refers to lands falling under Phase 1 of R.A. No. 9700, where the basic formula shall be:LV = Land Value
CNI = Capitalized Net Income which refers to the gross sales (AGP x SP) with assumed net income rate of 20% capitalized at 0.12
Expressed in equation form:
(AGP x SP) x 0.20
CNI = ______________________
0.12
Where:
AGP = Annual Gross Production corresponding to the latest available 12 month's gross production immediately preceding 30 June 2009. The AGP shall be secured from the Department of Agriculture (DA) or Bureau of Agriculture Statistics (BAS). The AGP data shall be gathered from the barangay or municipality where the property is located. In the absence thereof, AGP may be secured within the province or region.
SP = The average of the latest available 12 months' selling prices prior to 30 June 2009 such prices to be secured from the Department of Agriculture (DA) or Bureau of Agricultural Statistics (BAS). If possible, SP data shall be gathered from the barangay or municipality where the property is located. In the absence thereof, SP may be secured within the province or region.
MV = Market Value per Tax Declaration which is the latest Tax Declaration and Schedule of Unit of Market Value (SUMV) issued prior to 30 June 2009. MV shall be grossed-up up to 30 June 2009.
The reckoning date of the AGP and SP shall be June 30, 2009.39
Lv = (CNI x 0.60) + (CS x 0.30) + (MV x 0.10)The SAC, which the CA affirmed, held that, as per report of the commissioner, all three (3) relevant factors mentioned in either A.O. No. 2, series of2009 and/or A.O. No. 1, series of 2010 are present. Thus, the three-factor formula prescribed in A.O. No. 1, series of 2010 is applicable.41 The SAC then arrived at the following computation:
Where:LV = Land Value
CNI = Capitalized Net Income which refers to the gross sales (AGP x SP) with assumed net income rate of 20% capitalized at 0.12.
Expressed in equation form:
(AGP x SP) x 0.20
CNI = ______________________
0.12
Where:
AGP = Annual Gross Production corresponding to the latest available 12 month's gross production immediately preceding 01 July 2009. The AGP shall be secured from the Department of Agriculture (DA) or Bureau of Agriculture Statistics (BAS). The AGP data shall be gathered from the barangay or municipality where the property is located. In the absence thereof, AGP may be secured within the province or region.
CS = Comparable Sales (based on fair market value Equivalent to 70% of BIR Zonal Value).
SP = The average of the latest available 12 months' selling prices prior to 01 July 2009 such prices to be secured from the Department of Agriculture (DA) or Bureau of Agricultural Statistics (BAS). If possible, SP data shall be gathered from the barangay or municipality where the property is located. In the absence thereof, SP may be secured within the province or region.
MV = Market Value per Tax Declaration which is the latest Tax Declaration and Schedule of Unit of Market Value (SUMV) issued prior to 01 July 2009. MV shall be grossed-up up to 01 July 2009.
In case CS is not present, the formula shall be:
LV= (CNI x 0.90) + (MV x 0.10)
The reckoning date of the AGP and SP shall be July 01, 2009.40
(AGP x SP) x 0.20The Land Bank opposed the computation, arguing that the subject properties fall under II. B of DAR A.O. No. 1, series of 2010 - those P.D. No. 27 claims with the Land Bank where the DAR valuation is rejected or undergoing just compensation case in court. Hence, the formula that should be used is that provided in IV. 1 of the said administrative order, to wit:
CNI = _____________________
0.12
= (5,900 x P9.00) x 0.20
_____________________
0.12
= P88,500.00
CS = P20.00 zonal value/square meter x 10,000 sq. m.
= P200,000.00
MV = P30,100.00 x 100% x 1.60
= P48,160.00
LV = (CNI x 0.60) + (CS x 0.30) + (MV x 0.10)
= (88,500.00 x 0.60) + (200,000.00 x 0.30) + (48,160.00 x 0.10)
= 53,100.00 + 60,000.00 + 4,816.00
= P117,916.00 per hectare
Total LV = LV x area acquired
= 117,916.00 x 2.4975 hectares
= P294.495.20
2. Market Value per Tax Declaration (MVTD):
CROPS PLANTED ANNUAL GROSS PRODUCTION
(AGP) SELLING PRICE
(P) NIR CAPITALIZATION RATE CNI Rice-irrigated 5,900 kg. 9.00/kg. 20% .12 P88,500.00
3. Unit Land Value (ULV) Computation:
ACTUAL LAND USE PRODUCTIVITY CLASSIFICATION UNIT MARKET VALUE
(P) LOACTION ADJ. FACTOR REGIONAL CONSUMER PRICE INDEX
(RCPI) ADJUSTED UMV Rice-irrigated 43,750.00 100% 1.382 P60,462.50
The Court thus finds and so holds that the provision of AO No. 2, series of 2009, insofar as it distinguishes the applicability of Sec. 17 of RA [No.] 6657, as amended by RA No. 9700, is void and inapplicable in the determination of just compensation because it is contrary to the spirit ofRA No. 9700 which never made a distinction on the applicability of Sec. 17; it is contrary to the holding in LBP v. Dumlao, et al., supra, which upholds the harmonization of the formulae for the computation of just compensation both under PD No. 27 and RA No. 6657; it is violative of the "equal protection clause" of the Constitution; and it is unreasonable even as it unduly impinges on the prerogative of the special agrarian court to determine the amount of just compensation.48Perusal of A.O. No. 2, series of2009, would show that the "distinction" made was merely to emphasize that those lands would have to be resolved and finally valued under Sec. 17, R.A. No. 6657, as amended, instead of under P.D. No. 27 and E.O. No. 228. The same provisos were reiterated in DAR A.O. No. 01, series of 2010. It was, certainly, in keeping with the harmonization of the formulas in the computation of just compensation.
C.1 The following rules shall be observed in the computation of CS:In this case, the SAC did not take into consideration any comparable sale transactions because records did not show any. The reported P20.00/sq. m. zonal value of the land was simply multiplied by 10,000 sq. m. to arrive at the amount of P200,000.00 as the CS, a formula that is not one of those abovementioned. The SAC should not have forced using the 3-factor formula considering that no Comparable Sales was reported. Instead, it should have opted using an alternative formula provided by the rules which the data gathered permits. The 2-factor formula of LV = (CNI x 0.90) + (MV x 0.10) would have been the better alternative. Clearly, the SAC failed to abide by the implementing rules of the agrarian law and deviated therefrom without any justification.d.1 If there are two or more STs and MVM and/or AC are present:
- As a general rule, there shall be at least three (3) Sales Transactions.
At least one comparable sales transaction must involve land whose area is at least ten percent (10%) of the area being offered or acquired but in no case less than one hectare. The other transaction/s should involve land whose area is/are at least one hectare each.- If there are more than three (3) STs available in the same barangay, all of them shall be considered.
- If there are less than three (3) STs available, the use of STs may be allowed only if AC and/or MVM are/is present.
- Depending on the presence of applicable sub-factors, the following formulae shall be used:
STA + MVM + AC
d.1.1 CS = ________________ OR
3
STA + MVM
d.1.2 CS = ________________ OR
2
STA + AC
d.1.3 CS = ________________
2
WHERE:
STA is the average of available STs or as expressed in equation form:ST1 + ______ +STN
STA = _____________________
No. of STs
d.2 If there is only one STand AC and/or MVM are/is available:ST + MVM + AC
d.2.1 CS = _______________ OR
3
ST + MVM
d.2.2 CS = ________________ OR
2
ST + AC
d.2.3 CS = _______________
2
d.3 If three or more STs are present and AC and MVM are not available:
CS = STA
d.4. If AC and/or MVM are/is present and no ST is available:AC+MVM
d.4.1 CS = _________________ OR
2
d.4.2 CS = AC OR
d.4.3 CS = MVM
x x x x49
It is doctrinal that to be considered as just, the compensation must be fair and equitable, and the landowners must have received it without any delay. The requirement of the law is not satisfied by the mere deposit with any accessible bank of the provisional compensation determined by it or by the DAR, and its subsequent release to the landowner after compliance with the legal requirements set forth by R.A. No. 6657.Here, records showed that the state did not only immediately take the subject properties without paying just compensation,52 but it also subsequently distributed such landholdings to the farmer-beneficiaries as evidenced by the TCTs53 issued in their favor. Prado, as landowner, has been deprived of its properties. The imposition of such interest was to compensate the landowners for the income they would have made had they been properly compensated for their properties at the time of the taking.54
The amount allegedly deposited by the petitioner was only a partial payment that amounted to almost 18% of the actual value of the subject landholdings. It could be the basis for the immediate taking of the subject landholdings but by no stretch of the imagination can said nominal amount be considered substantial enough to satisfy the full requirement of just compensation, taking into account its income potential and the foregone income lost because of the immediate taking.
Notwithstanding the fact that the petitioner had immedia,tely deposited the initial valuation of the subject landholdings after its taking, the fact remains that up to this date, the respondent has not yet been fully paid. Thus, the respondent is entitled to legal interest from the time of the taking of the subject landholdings until the actual payment in order to place it in a position as good as, but not better than, the position that it was in before the taking occurred. The imposition of such interest is to compensate the respondent for the income it would have made had it been properly compensated for the properties at the time of the taking.51 (emphasis supplied)
While concededly far from perfect, the enumeration under Section 17 and the use of a basic formula have been the principal mechanisms to implement the just compensation provisions of the Constitution and the CARP for many years. Until a direct challenge is successfully mounted against Section 17 and the basic formulas, they and the collective doctrines in Banal, Celada and Yatco should be applied to all pending litigation involving just compensation in agrarian reform.61In fixing the just compensation in agrarian cases, courts are duty-bound to apply and consider the factors provided for in Sec. 17 of R.A. No. 6657, as amended, which are translated into the applicable DAR formulas. Although the courts have the power to make a final determination of just compensation as a result of its exercise of judicial discretion, a deviation from prevailing formulas on land valuation would be allowed for as long as such deviation is rational and amply substantiated.
Endnotes:
1Rollo (G.R. No. 208004), pp. 99-112; penned by Judge Frank E. Lobrigo.
2 Id. at 113-114.
3 Id. at 32-53; penned by Associate Justice Marlene Gonzales-Sison, with Associate Justices Hakim S. Abdulwahid and Edwin D. Sorongon, concurring.
4 Id. at 54-55.
5Rollo (G.R. No. 210243), pp. 46-48; penned by Associate Justice Normandie B. Pizarro, with Associate Justices Andres B. Reyes, Jr. and Manuel M. Barrios, concurring.
6 Supra note 1.
7Rollo (G.R. No. 208004), p. 35.
8 676 Phil. 518 (2011).
9 600 Phil. 346 (2009).
10Rollo (G.R. No. 208004), p. 49.
11 Id. at 51A.
12 Id. at 43.
13 Id. at 48.
14Rollo (G.R. No. 210243), p. 47.
15 Id.
16Spouses Mercado v. Land Bank of the Phils., 760 Phil. 846, 856 (2015).
17Land Bank of the Philippines v. Dalauta, G.R. No. 190004, August 8, 2017.
18 G.R. Nos. 181912 & 183347, November 29, 2016.
19 Id.
20 Id. at 414-435.
21 Id. at 420-421.
22 Id. at 422.
23 Id. at 421.
24 Id. at 429.
25 Id. at 432.
26 Id. at 431.
27 Supra note 25.
28 Id. at 433.
29 Id. at 478-495.
30 Id. at 490.
31 Id.
32 Id. at 491.
33 Supra note 18.
34 Id.
35 Factors enumerated in Section 17 of RA No. 6657, such as the nature, actual use and income are considered in the determination of the CNI of a particular landholding.
36 Factors, such as the cost of acquisition of the land, the current value of like properties, loans secured from any government financing institution and 70% of the zonal valuation of the Bureau of Internal Revenue are considered as the CS sub-factors.
37 On the other hand, factors, such as the tax declarations and assessment made by government assessors were considered in the detennination of the MV factor.
38Rollo (G.R. No. 208004), p. 100.
39 Rules and Regulations on Valuation and Landowners Compensation Involving Tenanted Rice and Corn Lands Under Presidential Decree No. 27 and Executive Order No. 228, DAR Administrative Order No. 001-10, Fobruary 12, 2010.
40 Id.
41Rollo (G.R. No. 208004), p. 111.
42 Supra note 30.
43 Id.
44 Supra note 32.
45Rollo (G.R. No. 208004), p. 492.
46 Id.
47 All previously acquired lands wherein valuation is subject to challenge by landowners shall be completed and finally resolved pursuant to Section 17 of R.A. No. 6657, as amended.
In like manner, claims over tenanted rice and corn lands under P.D. 27 and E.O. 228 whether submitted or not to the Land Bank of the Philippines and not yet approved for payment shall be valued under R.A. 6657, as amended.
Landholdings covered by P.D. 27 and falling under Phase 1 ofR.A. No. 9700 shall be valued under R.A. No. 9700.
48Rollo (G.R. No. 208004), p. 105.
49 Revised Rules and Regulations Governing the Valuation of Lands Voluntarily Offered or Compulsorily Acquired, DAR Administrative Order No. 05-98.
50 G.R. No. 193987, March 13, 2017.
51 Id.
52Rollo (G.R. No. 208004), pp. 183-185.
53 Id. at 138-145.
54Land Bank of the Phils. v. Spouses Avanceña, 785 Phil 755, 765 (2016).
55Evergreen Manufacturing Corp. v. Republic, G.R. Nos. 218628 & 218631, September 6, 2017.
56Land Bank of the Philippines v. Phil-Agro Industrial Corp., G.R. No. 193987, March 13, 2017.
57 Supra note 54 at 763-764.
58 Supra note 55.
59Nacar v. Gallery Frames, 716 Phil. 267 (2013).
60 G.R. Nos. 181912 & 183347, November 29, 2016.
61 Id.
62 Supra note 55.