Case Digest (G.R. No. 163175) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Evergreen Manufacturing Corporation v. Republic of the Philippines, decided on 6 September 2017 under G.R. Nos. 218628 and 218631, Evergreen Manufacturing Corporation owned a 1,428.68-sqm parcel in Barangay Santolan, Pasig City (TCT No. PT-114857). The Department of Public Works and Highways (DPWH) filed an expropriation complaint on 22 March 2004 to acquire 173.08 sqm for the Marikina Bridge and Access Road project after negotiations failed. DPWH deposited ₱1,038,480 (100% of the BIR zonal valuation of ₱6,000/sqm) and, following an agreement with Evergreen, obtained possession in 2006 via writ of possession. The sole issue at trial was just compensation. In October 2007, the court appointed three commissioners whose appraisal reports valued the expropriated land at ₱15,000, ₱37,500, and ₱30,000 per sqm. On 30 June 2011, the RTC fixed compensation at ₱25,000/sqm (₱3,288,520 net) and denied other claims; motions for reconsideration were denied on 3 November 2011. The Court of Case Digest (G.R. No. 163175) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Property
- Evergreen Manufacturing Corporation (Evergreen) is the registered owner of a 1,428.68 sqm parcel in Barangay Santolan, Pasig City (TCT No. PT-114857).
- The Republic of the Philippines, represented by the Department of Public Works and Highways (Republic-DPWH), sought to expropriate 173.08 sqm (Subject Premises) for the Marikina Bridge and Access Road project.
- Expropriation Proceedings
- Republic-DPWH offered negotiated purchase at the BIR zonal valuation of ₱6,000/sqm; Evergreen declined, prompting the filing of the expropriation complaint on 22 March 2004.
- Evergreen opposed, alleging lack of necessity, impairment of leasehold contracts, and sought either dismissal or, alternatively, reliefs including re-survey, new titles, and incidental expenses.
- Deposit and Possession
- On 19 August 2004, Republic-DPWH deposited ₱1,038,480 (100% of zonal valuation) and moved for a writ of possession; the RTC issued it on 6 December 2004.
- Entry disputes were resolved by agreement on 21 April 2006; Evergreen withdrew the deposit by leave of court on 15 November 2006.
- Determination of Just Compensation
- Parties agreed at pre-trial to limit issues to the amount of just compensation; on 15 October 2007, three commissioners were appointed.
- Separate appraisal reports recommended: ₱15,000/sqm (City Assessor), ₱37,500/sqm (Atty. Wy), and ₱30,000/sqm (Atty. Migrino).
- RTC and CA Rulings
- RTC Decision (30 June 2011): fixed compensation at ₱25,000/sqm totaling ₱3,288,520 (net of deposit); denied other claims; motions for reconsideration denied on 3 November 2011.
- CA Decision (26 June 2014): increased compensation to ₱35,000/sqm totaling ₱6,057,800 minus deposit; denied interest and consequential damages; recon denied on 25 May 2015.
- Supreme Court Petitions
- Evergreen’s petition (G.R. No. 218628, filed 3 August 2015) challenged denial of interest on compensation.
- Republic-DPWH’s petition (G.R. No. 218631, filed 29 July 2015) contested the basis and quantum of just compensation.
Issues:
- Evergreen’s Issue
- Whether Evergreen is entitled to legal interest on the balance of just compensation from filing of complaint until payment in full.
- Republic-DPWH’s Issues
- Whether the CA erred in fixing just compensation at ₱35,000/sqm on these grounds:
- The commissioners’ reports are hearsay and lack documentary support.
- Valuation must reflect the property’s value as of the date of taking or filing of complaint.
- Prior BOC valuation in LRTA case is not binding precedent for all expropriations.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)