Just Compensation Under CARP: Valuing Land at the Time of Taking
The Supreme Court clarifies that just compensation for CARP-acquired land is valued at the time of taking, guided by Section 17 factors and DAR formulas.
The valuation of agricultural land acquired under the Comprehensive Agrarian Reform Program (CARP) is one of the most contested areas of Philippine property law. In Land Bank of the Philippines v. Rural Bank of Hermosa (Bataan), Inc. (G.R. No. 181953, July 25, 2017, 814 Phil. 157), the Supreme Court En Banc laid down clear guideposts for the bench, the bar, and landowners: just compensation must be fixed as of the time of taking, and courts must reckon with the valuation factors in Section 17 of Republic Act No. 6657, as translated into Department of Agrarian Reform (DAR) formulas, before deviating from them.
The Dispute Over a Bataan Parcel
Rural Bank of Hermosa owned two agricultural parcels in Saba, Hermosa, Bataan, totaling 2.1718 hectares. It voluntarily offered the land for sale to the government under CARP, but only 1.572 hectares were acquired. The Land Bank of the Philippines (LBP) valued the property at P28,282.09 using the formula under DAR Administrative Order No. 17, series of 1989, as amended:
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