Facts:

The case centers around the Bank of the Philippine Islands (BPI) as the petitioner and the National Power Corporation (NAPOCOR) as the respondent, with the decision rendered on November 10, 2004, by the Supreme Court of the Philippines. The initial proceedings took place in the Regional Trial Court (RTC) of Imus, Cavite, where the trial court assessed the just compensation for a portion of BPI’s land in Barrio Bucal, Dasmariñas, Cavite, following a complaint filed by NAPOCOR on April 15, 1996, for expropriation pursuant to eminent domain. NAPOCOR sought this action to implement its Dasmariñas-Zapote 230 KV Transmission Line Project. On August 1, 1996, NAPOCOR deposited the assessed value of the property, amounting to P3,013.60, with the Philippine National Bank located in Quezon City. Shortly after, NAPOCOR notified BPI of its intention to take possession of the property, which led to the issuance of a writ of possession by the trial court. BPI's initial motion for particula

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Facts:

Expropriation Proceedings Initiation

• On April 15, 1996, National Power Corporation (NAPOCOR) filed a Complaint for Eminent Domain seeking to expropriate a portion of Bank of the Philippine Islands’ (BPI) property in Barrio Bucal, Dasmariñas, Cavite for its Dasmariñas-Zapote 230 KV Transmission Line Project.
• In compliance with Section 2 of Rule 67 of the Rules of Court, on August 1, 1996, NAPOCOR deposited P3,013.60 with the Philippine National Bank, NPC Branch, representing the assessed value of the property.

Notice and Initial Court Actions

• On August 15, 1996, NAPOCOR notified BPI via registered mail of its intention to take possession of the property.
• The trial court granted an urgent ex-parte motion for the issuance of a writ of possession, authorizing NAPOCOR to enter and take possession of the premises.
• A prior motion for a bill of particulars by BPI was denied, prompting BPI to move for dismissal of the case, which was granted without prejudice to its reinstatement.
• NAPOCOR’s subsequent motion for reconsideration led the trial court to reinstate the case.

Determination of Just Compensation

• On November 28, 1997, the trial court designated three commissioners – Mr. Lamberto C. Parra (Provincial Assessor of Cavite), Mr. Regalado Andaya (Municipal Assessor of Dasmariñas, Cavite), and Mr. Rodolfo D. Leonen (defendant’s representative) – to assess the just value of the expropriated property.
• On February 26, 1999, the commissioners issued their Report:

- They assessed the property area at 75.34 square meters and valued it at P10,000 per square meter, amounting to P753,400.00. - They recommended an additional payment of P524,660.00 as severance damage, setting the total at P1,278,060.00. - An undated Commissioners’ Valuation Report indicated that the market data approach was used, basing the value on recent sales and listings of comparable properties within the vicinity. - Declaring that the property had been lawfully expropriated and awarding just compensation at P10,000 per square meter (totaling P753,400.00), - Fixing each commissioner’s fee at P10,000.00, - Ordering payment with legal interest from the date of possession.

Appeal and Review

• NAPOCOR, after its motion for reconsideration was denied, appealed the decision.
• The Court of Appeals reversed the trial court’s decision:

- The just compensation was reduced to P3,000 per square meter, - Each commissioner’s fee was likewise fixed at P3,000.

Underlying Contentions

• BPI maintained that:

- The original valuation by the commissioners was based on clear evidence of prior sales and an acceptable market valuation method. - NAPOCOR was estopped from questioning the valuation given that its own nominee had concurred with the commissioners’ findings.

Supporting Evidence and Market Valuation Discrepancies

• The trial records and commissioners’ reports were contrasted with Resolution No. 08-95 of the Provincial Appraisal Committee of Cavite, dated October 25, 1995, which assessed local lots at P3,000 per square meter.
• The Court of Appeals noted:

- A discrepancy of 233% between the commissioners’ valuation and the valuation fixed by the Provincial Appraisal Committee. - The fact that over 70% of lot owners in the area had accepted the price set by the Provincial Appraisal Committee. - One of the commissioners (Mr. Parra) had been a signatory of the said Resolution.

Issue:

• Whether the Court of Appeals gravely abused its discretion by reversing the trial court’s decision and fixing the just compensation at P3,000 per square meter instead of P10,000 per square meter.
• Whether the findings of fact by the Court of Appeals, in reducing the valuation, were contrary to those of the trial court and thus amounted to a manifest error considering the clear evidence presented by the commissioners.
• Whether the weight given to the market valuation data from Resolution No. 08-95 was justified in determining the fair market value of the expropriated property.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)