180827 Case Digest.docx - 7 Landbank vs CA GR No 118712...

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7. Landbank vs CA, GR No. 118712, July 5, 1996 & DAR vs CA, GR No. 118745, July 5, 1996 Ratio: When the law speaks in clear and categorical language, there is no reason for interpretation or construction, but only for application. Thus, recourse to any rule which allows the opening of trust accounts as a mode of deposit under Section 16(e) of RA 6657 goes beyond the scope of the said provision and is therefore impermissible. Facts: The case involves how the government pays “just compensation” in expropriation proceedings. Petitioners filed their respective motions for reconsideration contending mainly that, contrary to the Court’s conclusion, the opening of trust accounts in favor of the rejecting landowners is sufficient compliance with the mandate of RA 6657. Sec. 16, RA 6657. Procedure for Acquisition of Private Lands – x x x x x x xxx (e) Upon receipt by the landowner of the corresponding payment or, in case of rejection or no response from the landowner, upon deposit with an accessible bank designated by the DAR of
the compensation in cash or in LBP bonds in accordance with this Act, the DAR shall take immediate possession of the land and shall request . . .” Moreover, it is argued that there is no legal basis for allowing the withdrawal of the money deposited in trust for the rejecting landowners pending the determination of the final valuation of their properties. Issue: Whether or not the opening of trust accounts is sufficient compliance with the mandate of RA 6657. Ruling: No, the opening of trust accounts is not sufficient compliance. The provision is very clear and unambiguous, foreclosing any doubt as to allow an expanded construction that would include the opening of “trust accounts” within the coverage of the term “deposit.” Accordingly, we must adhere to the well-settled rule that when the law speaks in clear and categorical language, there is no reason for interpretation or construction, but only for application. Thus, recourse to any rule which allows the opening of trust accounts as a mode of deposit under Section 16(e) of RA 6657 goes
beyond the scope of the said provision and is therefore impermissible. Notes: The rule-making power must be confined to details for regulating the mode or proceedings to carry into effect the law as it had been enacted, and it cannot be extended to amend or expand the statutory requirements or to embrace matters not covered by the statute. Any resulting discrepancy between administrative regulations and provisions of the law will always be resolved in favor of the basic law.
8. South Pacific Sugar Corp. vs. CA GR No. 180462, February 9, 2011 Facts: 1999 – the government projected a shortage of some 500,000 metric tons of sugar due to the effects of El Nio and La Nia phenomena.

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