Case Digest (G.R. No. 155065) Core Legal Reasoning Model
Facts:
The case involves the National Power Corporation (NPC) as the petitioner against respondents Petrona O. Dilao, Fidel T. Osmeña, Isabel T. Osmeña, Celestina O. Galon, Potenciana O. Batucan, Trinidad T. Osmeña, Lulia T. Osmeña, Lourdes O. Daffon, Victoria O. Barriga, Juan T. Osmeña Jr., and Estefania Enriquez. The controversy arose when NPC filed a complaint for expropriation on March 19, 1996, before the Regional Trial Court (RTC) of Danao City, Branch 25, aiming to acquire parcels of land situated in Baring and Cantumog, Carmen, Cebu, as part of its Leyte-Cebu Interconnection Project. The complaint concerned 7,281 square meters of the 25,758 square meters co-owned by Petrona Dilao and her siblings, and 7,879 square meters of the 17,019 square meters owned by Enriquez.
NPC immediately filed an urgent ex parte motion for the issuance of a writ of possession, which the RTC granted on May 9, 1996. A Board of Commissioners was appointed to determine just compensation. The commission
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Case Digest (G.R. No. 155065) Expanded Legal Reasoning Model
Facts:
- Parties and Context
- National Power Corporation (NPC) filed a complaint for expropriation on March 19, 1996, involving parcels of land in Baring and Cantumog, Carmen, Cebu.
- Defendants/respondents included Petrona O. Dilao and several siblings (co-owners of a land portion), and Estefania Enriquez, owner of another parcel.
- Subject Matter of Expropriation
- The complaint covered:
- NPC intended to use the lands for the Leyte-Cebu Interconnection Project, specifically for transmission lines and right-of-way easements.
- Proceedings and Motions
- NPC filed an urgent ex parte motion for writ of possession on March 20, 1996, granted on May 9, 1996.
- Dilao filed an answer with counterclaim while Enriquez did not respond.
- A Board of Commissioners was appointed to determine just compensation.
- Commissioners' Report and Trial Court Decision
- Commissioners reported (April 15, 1999) average appraisal of P516.66 per square meter for the Dilao properties.
- NPC opposed the appraisal, invoking R.A. No. 6395, Section 3A, arguing compensation for right-of-way easement should not exceed 10% of market value since the land remained agricultural.
- On November 10, 1999, the trial court adopted the commissioners' appraisal and awarded just compensation accordingly, including P250,000.00 for improvements.
- Appeals and Procedural Posture
- NPC filed a Notice of Appeal but failed to perfect it within the reglementary period due to non-filing of a record on appeal; the trial court denied their appeal on January 17, 2000.
- NPC’s motion for reconsideration and petition for relief were denied.
- Dilao et al.’s motion for execution of judgment was granted August 17, 2001.
- NPC filed a petition for certiorari with the Court of Appeals challenging the denial of their appeal and execution order; the petition was denied.
- NPC brought the case to the Supreme Court, arguing deprivation of due process and incorrect application of the rules on record on appeal and jurisdiction.
Issues:
- Whether the failure of NPC to file a record on appeal in the expropriation case justified the dismissal of its appeal.
- Whether a complaint for expropriation under Rule 67 of the Rules of Civil Procedure is a "special proceeding" or falls under the category of "multiple or separate appeals" requiring a record on appeal under Rule 41, Section 2.
- Whether the trial court acquired jurisdiction over defendant Enriquez despite her failure to file an answer or appear.
- Whether the commissioners’ and trial court’s valuation of just compensation based on full market value for the right-of-way easement, instead of limiting it to 10% of market value as provided by Section 3A of R.A. No. 6395, was proper.
- Whether the imposition of easement for transmission lines constitutes a taking within the power of eminent domain necessitating compensation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)