Title
Benguet Consolidated, Inc. vs. Republic
Case
G.R. No. 71412
Decision Date
Aug 15, 1986
The Republic expropriated Benguet Consolidated’s mining claims for the Philippine Military Academy, with compensation fixed at P7,532.46 plus interest. The Supreme Court upheld the condemnation as lawful and the compensation as just.
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Case Digest (G.R. No. 71412)

Facts:

Background of the Case:
On June 18, 1958, the Republic of the Philippines filed a complaint for expropriation against ten defendants, including Benguet Consolidated, Inc. (now Benguet Corporation), to establish a permanent site for the Philippine Military Academy. The Republic claimed it had occupied the area since May 6, 1950, and installed improvements worth P3,000,000. The Appraisal Committee estimated the fair market value of the affected properties at P532,371.40.

Petitioner’s Mining Claims:
Benguet Consolidated owned four mining claims (JEAN, DOLORES FR, NUGGET FR, and SMOKE) with a total area of 25.1082 hectares, located between 1930 and 1933. The petitioner filed a motion to dismiss, arguing that the Republic did not need the areas covered by its claims, which were rugged and unsuitable for the Academy. It also contended that the expropriation violated the law.

Procedural History:
The trial court issued an order on December 28, 1955, declaring the Republic’s right to condemn the property upon payment of just compensation. Benguet Consolidated objected, claiming it had not waived its right to challenge the condemnation. A Board of Commissioners was formed to assess compensation, and after extensive hearings, they recommended a total payment of P43,703.37 to the defendants. The trial court rejected the report and later issued a decision omitting an award for Benguet Consolidated. After several motions, the trial court fixed compensation for the petitioner’s surface area at P128,051.82 with interest.

Appeal and Appellate Court Decision:
Only the Republic and Benguet Consolidated appealed. The Intermediate Appellate Court reversed the trial court’s decision, ordering the Republic to pay Benguet Consolidated P7,532.46 for its mineral claims. The petitioner contested this amount, asserting it was unjustly low and that the condemnation was contrary to law.

Issue:

  1. Whether the condemnation of the petitioner’s mineral claims is lawful.
  2. Whether the Commissioners’ Report, which fixed the compensation at P7,532.46, is valid and just.
  3. Whether the procedural steps in the expropriation proceedings were properly followed.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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