Title
City of Manila vs. Comales
Case
G.R. No. 10076
Decision Date
Oct 28, 1915
The City of Manila seeks to condemn a property for the purpose of building a street, and after considering the evidence, the court awards the defendants a total of P33,138.28 for the expropriated land and structures.
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Case Digest (G.R. No. 10076)

Facts:

  • The case City of Manila vs. Comales (G.R. No. 10076) was decided by the Supreme Court of the Philippines on October 28, 1915.
  • The City of Manila, as the plaintiff-appellant, sought to condemn properties owned by Fernanda Felisa Comales and her children, the defendants-appellants.
  • The condemnation aimed to facilitate the construction of a street connecting Calle Marques de Comillas to Calle Nozaleda, passing through Calle San Marcelino and Taft Avenue.
  • Legal proceedings began on May 22, 1913, in the Court of First Instance of the City of Manila.
  • The city acquired most of the necessary land, but the properties in question were essential for project completion.
  • After hearings, the court recognized the necessity of the condemnation and appointed commissioners to appraise the properties, which included various structures.
  • The commissioners recommended a compensation amount of P31,785.15 for the expropriated properties.
  • Both parties appealed, claiming errors in the valuation and compensation awarded.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the defendants, awarding them P33,138.28 for the expropriated land and structures.
  • The court determined that property owners should not be charged for improvements needed for public use.
  • The valuation methods used by the commissi...(Unlock)

Ratio:

  • Compensation in expropriation cases must reflect the reasonable market price at the time of expropriation.
  • Property owners should not be unjustly enriched or deprived of fair compensation.
  • Market value is based on what a willing buyer would pay, not on arbitrary deductions for...continue reading

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