Landbank v. SPS Banal
G.R. No. 143276, July 20, 2004

Facts: 

Respondents Spouses  Banal  are  the  registered  owners  of  more than 19 hectares  of  agricultural  land  situated  in Camarines  Norte.  A  portion  of  the  land  was  compulsorily  acquired  by  DAR  pursuant  to  the  Comprehensive Agrarian Reform Law of 1988. Petitioner Landbank valued the expropriated portion at P173,918.55. Unsatisfied with the Landbank valuation and the subsequent affirmance of such by PARAD, Respondents filed before the RTC a petition for determination of just compensation. DAR and the Landbank were impleaded as respondents. After the pre-trial, the court issued an Order dispensing with the hearing and directing the parties to submit their respective memoranda. Trial court computed the just compensation for a total of P703,137.00, which is beyond respondents  valuation  of  P623,000.00.  In  concluding  that  the  valuation  of  respondents  property,  the RTC  merely took judicial notice of the average production figures in another case pending before it and applied the same to instant case without conducting a hearing.


Issue: 

Whether or not a court may take judicial notice of the records of one case pending before it and apply the same to another case also pending with it without conducting trial and without the knowledge or consent of the parties.


Held: 

No. 

Well-settled is the rule that courts are not authorized to take judicial notice of the contents of the records of other cases even when said cases have been tried or are pending in the same court or before the same judge. They may only do so "in the absence of objection" and "with the knowledge of the opposing party," which are not obtaining here.

Furthermore, the Rules of Court shall apply to all proceedings before the Special Agrarian Courts. In this regard, Section 3, Rule 129 of the Revised Rules on Evidence is explicit on the necessity of a hearing before a court takes judicial notice of a certain matter, thus:

"SEC. 3. Judicial notice, when hearing necessary. – During the trial, the court, on its own initiative, or on request of a party, may announce its intention to take judicial notice of any matter and allow the parties to be heard thereon.

"After the trial, and before judgment or on appeal, the proper court, on its own initiative or on request of a party, may take judicial notice of any matter and allow the parties to be heard thereon if such matter is decisive of a material issue in the case." 

The RTC failed to observe the above provisions.