Land Bank of the Philippines v. Lajom, G.R. No. 184982, 20 August 2014

Constitutional Law; Agrarian Reform; Just Compensation; Time of Taking – Just compensation must be valued at the time of the taking, or the “time when the landowner was deprived of the use and benefit of his property” which, in this case, is reckoned from the date of the issuance of the emancipation patents. Hence, the valuation of the subject portion must be based on evidence showing the values prevalent on such time of taking for like agricultural lands

Constitutional Law; Agrarian Reform; Just Compensation; Award of Interest; Prospectivity of Nacar Ruling – With respect to the commonly raised issue on interest, the RTC may impose the same on the just compensation award as may be justified by the circumstances of the case and in accordance with prevailing jurisprudence. The Court has previously allowed the grant of legal interest in expropriation cases where there was delay in the payment of just compensation, deeming the same to bean effective forbearance on the part of the State. To clarify, this incremental interest is not granted on the computed just compensation; rather, it is a penaltyimposed for damages incurred by the landowner due tothe delay in its payment. Thus, legal interest shall be pegged at the rate of 12% p.a. from the time of taking until June 30, 2013. Thereafter, or beginning July 1, 2013, until fully paid, just compensation shall earn interest at the new legal rate of 6% p.a., conformably with the modification on the rules respecting interest rates introduced by Bangko Sentral ng Pilipinas Monetary Board Circular No. 799, Series of 2013.

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