Case Digest (G.R. No. 232119)
Facts:
National Grid Corporation of the Philippines v. Getulia A. Gaite and the Heirs of Trinidad Gaite, G.R. No. 232119, August 17, 2022, the Supreme Court Third Division, Gaerlan, J., writing for the Court.Petitioner National Grid Corporation of the Philippines (NGCP) filed a Complaint for Eminent Domain on April 15, 2010 before the Regional Trial Court (RTC), Iligan City, Branch 3, seeking to acquire portions of agricultural lots owned by Getulia A. Gaite and the heirs of Trinidad Gaite for the Abaga‑Kirahon 230 kV Transmission Line Project. NGCP alleged the areas affected and, by certification from Landbank, deposited P186,063.42 (equivalent to 100% of the BIR zonal value) and sought possession.
On August 24, 2010 NGCP moved ex parte for a writ of possession attaching the Landbank certification; the RTC issued a Writ of Possession on July 8, 2011 placing NGCP in actual possession. Commissioners were later appointed to determine fair market value. A joint commissioners’ report recommended P60.00 per square meter (sqm.), based on ocular inspection and nearby deeds of sale; however, Commissioner Atty. Raymundo C. Capistrano submitted a separate report on March 17, 2014 recommending P300.00 per sqm., citing city ordinances he asserted reclassified the land as “agri‑industrial” and a nearby DPWH sale at P250.00 per sqm.
The RTC adopted Atty. Capistrano’s separate report and, in its August 5, 2014 Decision, awarded just compensation based on P300.00 per sqm. (total P2,391,910.80 less the deposit), legal interest at 6% per annum from date of taking, and honoraria to commissioners. NGCP’s motion for reconsideration was denied June 17, 2015; NGCP filed a Notice of Appeal on September 21, 2015. The Court of Appeals (CA) dismissed the appeal by Resolution dated October 27, 2016 for failure to file an appellant’s brief; NG...(Pro-only)
Issues:
- Did the Court of Appeals err in dismissing NGCP’s appeal for failure to file an appellant’s brief and in refusing to exercise its discretion to admit the belated brief?
- Did the RTC err in adopting Commissioner Atty. Capistrano’s separate report fixing just compensation at P300.00 per sqm. instead of the joint commissioners’ recommendation of P60.00 per sqm.?
- What interest rate on just compensation is proper given the taking and ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)