Case Digest (G.R. No. 165828) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In National Power Corporation vs. Heirs of Macabangkit Sangkay (G.R. No. 165828, August 24, 2011), the petitioner National Power Corporation (NPC), under its charter (Republic Act No. 6395), constructed the Agus River Hydroelectric Power Plant Project in the 1970s, which included underground tunnels diverting water through private lands in Ditucalan, Iligan City. In November 1997, the Heirs of Macabangkit—Cebu, Batowa-an, Sayana, Nasser, Manta, Edgar, Putri, Mongkoy, and Amir—owners of a 221,573 m² parcel, sued NPC in the Regional Trial Court (Branch 1, Iligan City) for recovery of damages and property, or alternatively for just compensation, alleging that NPC surreptitiously built a tunnel under their land in 1979 without their knowledge or consent, thereby destroying trees, reducing the land’s value, and causing noise and vibrations. NPC answered, invoking a mere easement under Section 3(i) of RA 6395 and asserting that any claim had prescribed. On August 13 and 18, 1999, the Case Digest (G.R. No. 165828) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- The National Power Corporation (NPC), under Republic Act No. 6395, built the Agus River Hydroelectric Power Plant in Mindanao during the 1970s, including underground tunnels completed in 1979.
- The tunnels diverted water from the Agus River to power stations (Agus V, VI, VII).
- Complaint by the Heirs of Macabangkit
- On November 21, 1997, nine heirs owning 221,573 sqm in Ditucalan, Iligan City, sued NPC in RTC for recovery of damages and property or, alternatively, just compensation.
- They alleged they belatedly discovered (in 1995) an underground tunnel built without consent, which diminished agricultural, commercial, industrial, and residential value, caused noise and shaking, and thwarted land transactions and developments.
- RTC Proceedings and Decisions
- NPC answered, claiming a mere easement under RA 6395, that the action prescribed, and raising defenses of prescription, estoppel, and laches.
- Ocular inspection (July 23, 1998) confirmed tunnel markings, damaged trees, and ground vibrations.
- RTC (Aug. 13, 1999) ruled for the heirs:
- Just compensation for 227,065 sqm at ₱500/sqm (₱113,532,500), plus interest.
- Monthly rentals of ₱30,000 (1979–1999) at 12% annual interest.
- Moral and exemplary damages of ₱200,000 each.
- Attorney’s fees at 15%, plus costs.
- Supplemental Decision (Aug. 18, 1999) added condemnation clause, vesting the tunnel easement in NPC upon payment.
- NPC appealed to CA; heirs sought execution; CA issued TRO; CA’s TRO later upheld by Supreme Court (May 4, 2006).
Issues:
- Whether the underground tunnel traversing the heirs’ land was sufficiently proven.
- Whether the heirs’ action for just compensation was barred by:
- The five-year prescriptive period under Section 3(i) of RA 6395; or
- Acquisitive prescription under Civil Code Articles 620 and 646 for continuous easements.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)