Case Digest (G.R. No. 60077) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In National Power Corporation v. Sps. Misericordia Gutierrez and Ricardo Malit (G.R. No. 60077, January 18, 1991), the government-owned National Power Corporation (NPC) sought to construct its 230 KV Mexico-Limay transmission line over lands covered by Tax Declarations Nos. 907, 4281 and 7582 belonging to Matias Cruz, heirs of Natalia Paule, and spouses Misericordia Gutierrez and Ricardo Malit. After amicable settlement with some landowners, NPC negotiated with the Malit spouses for the right-of-way easement over 760 square meters but failed to agree on compensation and filed an eminent domain proceeding on January 20, 1965, in the Court of First Instance of Pampanga. NPC deposited a provisional value of ₱973.00 with the Provincial Treasurer of Pampanga, was granted immediate possession, and the spouses withdrew the amount under court order. Three commissioners (one each for NPC, the defendants, and the court) were appointed to appraise the property. The NPC commissioner recomme... Case Digest (G.R. No. 60077) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Parties and Subject Matter
- National Power Corporation (NPC), a government-owned and controlled corporation under Commonwealth Act No. 120, is empowered to expropriate private property for public utility purposes, including the construction of electric transmission lines.
- NPC’s 230-kV Mexico-Limay transmission lines required a right-of-way over lands owned by spouses Misericordia Gutierrez and Ricardo Malit (Tax Declaration No. 7582), among others.
- Expropriation Proceedings
- After failed negotiations, NPC filed an eminent domain complaint on January 20, 1965, and deposited ₱973.00 as provisional value for the Malit–Gutierrez land, obtaining immediate possession.
- The trial court authorized the spouses to withdraw the deposit (September 30, 1965) and appointed three commissioners (one for NPC, one for the spouses, one for the court) to determine just compensation.
- Commissioners’ appraisals:
- NPC’s representative recommended an easement fee of ₱1.00 for the entire 760 sq. m.
- Spouses’ representative recommended ₱10.00 per sq. m. (₱7,600.00 total).
- Court’s representative recommended ₱5.00 per sq. m.
- Trial Court Decision (December 4, 1972): awarded ₱10.00 per sq. m. (₱7,600.00) plus ₱800.00 attorney’s fees.
- Trial Court Reconsideration (June 10, 1973): after ocular inspection, classified the land as partly agricultural and partly commercial, reduced award to ₱5.00 per sq. m. (₱3,800.00) and set aside attorney’s fees.
- Court of Appeals (March 9, 1982): in CA-G.R. No. 54291-R, affirmed the trial court’s ₱5.00 per sq. m. award with costs.
- NPC filed this petition for review on certiorari, raising the sole issue of whether only a simple easement fee is due or the full market value of the land.
Issues:
- Principal Issue
- Whether NPC’s acquisition of a right-of-way for its transmission lines constitutes a taking under the power of eminent domain that requires payment of full compensation based on the land’s market value, or merely a nominal easement fee.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)