Case Digest (G.R. No. 223660) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In National Power Corporation v. Elizabeth Manalastas and Bea Castillo, G.R. No. 196140, decided January 27, 2016, petitioner National Power Corporation (NAPOCOR), a government-owned and controlled corporation tasked with power generation and transmission, constructed a 230 KV line (Naga–Tiwi) and a 69 KV line (Naga–Tinambac) over respondents’ property under TCT No. 26263 between 1977–1978. Without respondents’ consent or prior expropriation proceedings, NAPOCOR occupied 26,919 sqm, denying respondents the intended subdivision use and causing financial loss. In July 2000, respondents, joined initially by their mother, Celedonia, and brother, Mariano, filed a complaint in the Regional Trial Court of Naga City seeking removal of the lines or just compensation at ₱800.00 per square meter. On November 17, 2006, the RTC ordered NAPOCOR to pay just compensation totaling ₱92,827,351.00 plus attorney’s fees of ₱100,000.00. On appeal, the Court of Appeals on September 9, 2010 affirme Case Digest (G.R. No. 223660) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of Case
- National Power Corporation (NPC) – government-owned and controlled corporation engaged in power generation, transmission and distribution.
- Respondents Elizabeth Manalastas and Bea Castillo – owners of parcel of land covered by TCT No. 26263.
- Transmission Line Construction and Impact
- Circa 1977–1978, NPC constructed a 230 kV line (Naga–Tiwi) and a 69 kV line (Naga–Tinambac) over respondents’ land (26,919 sqm) without their knowledge, consent or expropriation proceedings.
- Presence of the lines prevented development of the land as a subdivision, causing respondents’ alleged financial losses.
- Trial Court Proceedings
- July 2000 – respondents (joined by mother Celedonia and brother Mariano) filed complaint in RTC of Naga City, praying for removal of lines or just compensation at ₱800/sqm for 26,000 sqm.
- November 17, 2006 – RTC Decision ordered NPC to pay just compensation of ₱92,827,351.00 broken down as follows:
- Elizabeth and Bea: land value ₱53,816,461.00 plus 6% interest for 28 years (₱32,033,610.00) = ₱85,850,071.00
- Celedonia and Enrico: land value ₱1,000,200.00 plus 6% interest for 9 years (₱5,887,080.00) = ₱6,977,280.00
- Attorney’s fees of ₱100,000.00
- Court of Appeals and Present Petition
- CA Decision (Sept. 9, 2010) affirmed with modification, reducing award to Celedonia and Enrico to ₱1,678,908.00; held NPC bound by its own valuation recommendation (judicial admission).
- CA Resolution (Mar. 14, 2011) denied NPC’s motion for partial reconsideration.
- NPC filed Rule 45 petition before the Supreme Court, contending:
- Estoppel is inoperative against the government; inflation rate should not be included in just compensation.
- Just compensation determination is a judicial function; courts not bound by party’s formulation.
- Award of ₱85,850,071.00 unjustly enriches respondents.
Issues:
- Whether the inflation rate of the Philippine Peso may be included in computing just compensation for expropriated land.
- Whether estoppel binds the government to its agents’ or counsel’s erroneous valuation recommendations.
- Whether courts are bound to uphold a party’s formulation of just compensation absent legal basis.
- Whether the award as computed by the lower courts results in unjust enrichment of respondents.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)