G.R. No. 213582 - Odiamar vs. Valencia

On June 18, 1958, the Republic of the Philippines filed a complaint for expropriation before the then Court of First Instance of Benguet and Baguio against ten defendants, including Benguet Consolidated, Inc. (now Benguet Corporation).
The Government claimed the need for the property to establish and maintain a permanent site for the Philippine Military Academy, asserting that the area had been occupied since May 6, 1950, with substantial improvements amounting to at least P3,000,000.00.
An appraisal conducted under Administrative Order No. 144 (dated October 10, 1955) estimated that the total fair market value of the interests of all affected defendants would not exceed P532,371.40.

Benguet Consolidated, Inc. owned four mining claims (Jean, Dolores, Nugget, and Smoke) with a total area of 25.1082 hectares, located on dates ranging from August 24, 1930, to May 18, 1933.
The petitioner filed a motion to dismiss on two grounds:

It argued that the Republic neither occupied the areas covered by its mining claims nor made improvements thereon, and that the terrain was unsuitable for the Philippine Military Academy.
It contended that the expropriation, authorized by the President for privately owned mineral lands and interests, violated existing law regarding the petitioner’s claims.

The trial court, on December 28, 1955, temporarily suspended the hearing of the motion to dismiss pending an amicable settlement, and issued an order declaring that the Republic had a lawful right to expropriate the property (subject of condemnation) upon payment of just compensation.

Benguet Consolidated, Inc. opposed the condemnation order by asserting it had never waived its right to challenge the expropriation.
On February 23, 1960, the trial court noted on record that despite pending negotiations, the petitioner did not forfeit its right to contest the government's action.
A Board of Commissioners was then formed to assess the just compensation; its members included Engineer Ernesto C. Bengson, Attorney-Engineer Rolando J. Gamboa, and Mining Engineer Francisco G. Joaquin (who later resigned after eight hearings).
On February 28, 1963, following 56 additional hearings, the Board recommended just compensation of P43,703.37 for all ten defendants.
The trial court, however, rendered a decision on July 5, 1973, which awarded various sums to the defendants but notably excluded an explicit award for the petitioner’s four mining claims.
Subsequent motions by the petitioner (for clarification, new trial/reconsideration, and reopening the case) were directed at addressing its exclusion from the compensation award, but the trial court eventually fixed the petitioner’s just compensation for the surface rights of its claims at P128,051.82 (with interest and attorney’s fees) before denying a motion to reopen the case.

Only the Republic and Benguet Consolidated, Inc. appealed the trial court’s decision, and on June 28, 1985, the Intermediate Appellate Court rendered a decision that set aside the trial court’s earlier award.
The appellate decision condemned the petitioner’s mineral claims for public use and fixed the just compensation for the petitioner at P7,532.46, computed on a per-hectare basis (25.1082 hectares multiplied by the P300.00 rate for non-producing unpatented claims).
Notably, the decision also mentioned the necessity for legal interest—6% per annum from May 6, 1950 until July 29, 1974 and 12% thereafter until full payment—though the petitioner had contentious arguments regarding both the method of condemnation and the adequacy of the compensation amount.

Whether the government’s exercise of eminent domain in expropriating the petitioner’s mineral claims—despite the claims being perfected and segregated from the public domain—was lawful.
Whether the trial court erred by proceeding with an order of condemnation before the petitioner’s motion to dismiss had been finally resolved, in view of the Rules of Court governing expropriation proceedings.

Whether the Commissioners’ Report and subsequent award of P7,532.46 as just compensation—a figure based solely on the surface rights of the claims—adequately reflected the fair market value of the expropriated properties.
Whether the assessment process, based on the Schedule of Assessed Value of Mineral Lands and the submitted documentary evidence, was sufficient to support the compensation determined.

The petitioner’s shift from contesting the validity of the expropriation to challenging the quantum of compensation.
Whether the petitioner is estopped from raising procedural and substantive arguments concurrently after having abandoned its initial opposition to the expropriation.