Case Digest (G.R. No. 8231) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On November 23, 1994, Lucman G. Ibrahim, in his personal capacity and representing his co-heirs (Omar G. Maruhom, Elias G. Maruhom, Bucay G. Maruhom, Farouk G. Maruhom, Hidjara G. Maruhom, Rocania G. Maruhom, Potrisam G. Maruhom, Lumba G. Maruhom, Sinab G. Maruhom, Acmad G. Maruhom, Solayman G. Maruhom, Mohamad M. Ibrahim, and Caironesa M. Ibrahim), sued the National Power Corporation (NAPOCOR) before the Regional Trial Court of Lanao del Sur for recovery of possession and damages. They claimed ownership of three lots totaling 70,000 sqm (Survey Plan FP (VII-5) 2278). In 1978, NAPOCOR allegedly entered without consent and built underground tunnels beneath the land for its Agus hydroelectric projects. The existence of these tunnels was discovered by respondents in July 1992 and confirmed by NAPOCOR in November 1992. Respondents demanded that NAPOCOR vacate the subterrain area and pay damages, moral and exemplary damages, but NAPOCOR refused, asserting an easement in private lands Case Digest (G.R. No. 8231) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- In November 1994, Lucman G. Ibrahim and co-heirs sued the National Power Corporation (NAPOCOR) before the RTC of Lanao del Sur for recovery of possession and damages concerning 70,000 square meters of land (Lots 1, 2, 3 of Survey Plan FP (VII-5) 2278).
- They alleged that in 1978, NAPOCOR clandestinely constructed underground tunnels beneath their land for its hydroelectric projects without consent; discovery occurred in July–November 1992.
- Proceedings Below
- RTC Decision (Aug 7, 1996): denied dismantling, awarded just compensation of ₱48,005,000, back rentals of ₱7,050,974.40, moral damages of ₱200,000, and attorney’s fees of ₱200,000.
- Execution pending appeal was granted; NAPOCOR’s attempted appeals and motions for reconsideration were denied for being out of time or withdrawn.
- Respondents petitioned for relief from judgment (Oct 1996); RTC modified award (Sept 8, 1997) reducing just compensation and rentals.
- Both sides appealed to the Court of Appeals (CA). CA (June 8, 2005) set aside the modified judgment, restored the original award with deletion of moral damages and reduction of rentals to ₱6,888,757.40 and attorney’s fees to ₱50,000.
- NAPOCOR filed a Rule 45 petition for review in the Supreme Court.
Issues:
- Entitlement to Compensation
- Did NAPOCOR’s use of the sub-terrain area constitute a “taking” requiring just compensation?
- Were respondents deprived of beneficial enjoyment of their land, including subsoil rights under Article 437, Civil Code?
- Basis and Computation of Compensation
- Should valuation be based on the date of tunnel construction (1978) or on the date of discovery and confirmation of taking (1992)?
- Was the award of ₱1,000 per square meter, derived from adjacent Lot 1, a proper measure of fair market value?
- Were back rentals and attorney’s fees correctly computed and awarded?
- Procedural and Review Issues
- Whether creation of an easement without expropriation proceedings violated respondents’ due process and property rights.
- Whether the CA gravely abused its discretion in its factual findings on ownership, valuation, and damages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)