G.R. No. 221624 - National Transmission Corp. vs. Lacson-De Leon

Case Digest (G.R. No. 221624)
Expanded Legal Reasoning Model

Facts:

Background of the Case

National Power Corporation (NAPOCOR), later substituted by National Transmission Corporation (petitioner), initiated a special civil action for expropriation.
The expropriation involved a parcel of land measuring 39,347 square meters, which is only a portion of a larger lot (Lot No. 1074-B, totaling 874,450 square meters) covered by Transfer Certificate of Title No. T-428.
The purpose of the expropriation was to secure an easement of right-of-way for the construction and maintenance of the Bacolod-Cadiz 138 KV SC/ST Transmission Line for the Negros IV-Panay IV Project.

Pleadings, Motions, and Pretrial Proceedings

On February 28, 2002, NAPOCOR filed the expropriation complaint against Maria Teresa Lacson De Leon.
Maria Teresa Lacson De Leon subsequently filed a Motion to Dismiss on March 20, 2002, asserting that the registered owner was her nine children (the respondents).
The trial court, on July 3, 2002, directed NAPOCOR to amend its complaint to include all real parties-in-interest.
Summons were served; however, only one respondent could be located initially, while service by publication was ordered for the others.
On October 15, 2002, the trial court ordered the dismissal of Maria Teresa Lacson De Leon from the case.
By December 4, 2002, the remaining respondents formally filed their Answers and Manifestations, adopting a common responsive pleading.

Valuation and Evidence Gathering

On December 12, 2003, following a motion by NAPOCOR, the trial court directed the issuance of a Writ of Possession in favor of NAPOCOR upon proof of deposit equivalent to 100% of the property’s value based on the Bureau of Internal Revenue’s (BIR) zonal valuation.
Actual delivery of possession took place on February 2, 2004.
The board of commissioners was appointed and, on October 7, 2004, filed a Manifestation accompanied by a Narrative Report containing their valuation findings.

They conducted an ocular inspection and researched comparable properties within a five‐kilometer vicinity.
Due to conflicting evidence between the tax declarations (which classified the land as agricultural) and the City Planning and Development Office Certification (which classified it as residential), the board gave more weight to the latter.
The fair market value was initially recommended based on averaging the raw land values of three nearby subdivisions.

Trial Court Decision

The trial court ruled in favor of the respondents, ordering:

Just compensation amounting to PhP28,428,207.50 for the 39,347-square meter property.
Consequential damages amounting to PhP22,463,103.00 for a portion of the larger lot adversely affected by the installation of high-tension transmission lines (310,908 square meters being prejudiced).
The payment of attorney’s fees.

The decision was rendered on October 15, 2007.

Appeal and Subsequent Court of Appeals Proceedings

NAPOCOR filed a Notice of Appeal on November 26, 2007, contesting primarily the computation of just compensation.
The Court of Appeals affirmed the trial court’s decision with modifications:

The award for attorney’s fees was deleted.
Interest was imposed at 12% per annum on the just compensation from February 2, 2004, until full payment.

Later proceedings included:

A Motion for Reconsideration filed by NAPOCOR.
A Joint Motion for the Substitution of Parties and Counsel, which was granted by the Court of Appeals in its Resolution on November 18, 2015.

Contentions Regarding Valuation and Classification

Petitioner contested the method and timing of the valuation:

Argued that just compensation should be determined as of the filing date (February 28, 2002) rather than the date of actual taking.
Asserted that the property, based on tax declarations and actual use, was agricultural, not residential.
Claimed the averaging of three different residential/commercial subdivisions did not provide a proper basis for determining the fair market value.

Respondents maintained that:

The property classification as residential, as confirmed by prior certifications and local government resolutions, was proper.
The method adopted by the board of commissioners in determining fair market value was just and reasonable.

Issues:

Determination of Just Compensation

Whether the valuation for just compensation should be based on the date of filing the complaint (February 28, 2002) or the date of actual taking (February 2, 2004).
Whether the method of computing the fair market value based on averaging the raw land values of three subdivisions is sound, considering the non-comparability of their highest and best uses.

Classification of the Property

Whether the land should be classified as agricultural (as per tax declarations and actual use) or as residential (as per the Certification issued by the City Planning and Development Office and local government resolutions).
The impact of the property’s classification on the valuation and computation of just compensation.

Award of Consequential Damages

Whether the award of consequential damages, initially calculated as PhP22,463,103.00 (10% of the segregated area’s fair market value), was justified.
Whether the proper measure should be limited to 50% of the applicable zonal valuation (as derived from precedent in NAPOCOR v. Marasigan).

Imposition of Legal Interest

Whether the imposition of legal interest at 12% per annum from the date of taking until full payment, and subsequently at 6% per annum pursuant to BSP Circular No. 799, is proper.
How the delay in payment of just compensation and consequential damages affects the computation of interest.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. 221624) Core Legal Reasoning Model Expanded

Facts:

Case Digest (G.R. No. 221624) Expanded Legal Reasoning Model

Facts:

Issues:

Ruling:

Ratio:

Doctrine:

Case Digest (G.R. No. 221624)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. 221624)
Expanded Legal Reasoning Model