Case Digest (G.R. No. 223366)
Facts:
In National Transmission Corporation v. Oroville Development Corporation, G.R. No. 223366, decided on August 1, 2017 under the 1987 Constitution, TransCo constructed the Tagoloan-Pulangi 138 kV transmission line in 1983 over two parcels of land then owned by Reyes and Calingasan in Puerto, Cagayan de Oro. Those lands were later sold to Oroville and registered under TCT Nos. T-85121 and T-104365, respectively, with a combined area of 13,904 m². In November 2006, TransCo offered to purchase Oroville’s properties for the Abaga-Kirahon 230 kV line but refused Oroville’s rerouting request. In April 2007, Oroville sued for injunction and damages, praying for a temporary restraining order and ultimately agreed with TransCo to convert the case into an expropriation proceeding. In May 2010, the RTC provisionally deposited ₱7,647,200 as just compensation, directed a writ of possession in March 2011, and appointed three commissioners to value the land. Their valuations ranged from ₱1.20/m²Case Digest (G.R. No. 223366)
Facts:
- Background of Properties
- Two parcels in Barangay Puerto, Cagayan de Oro City originally titled in the names of Alfredo Reyes (OCT No. P-3) and Grace Calingasan (OCT No. P-13).
- 1983: TransCo constructed the Tagoloan–Pulangi 138 kV transmission line traversing these lands without prior expropriation or payment of compensation.
- Successive transfers of title resulted in respondent Oroville Development Corporation holding both parcels under TCT Nos. T-85121 and T-104365, totaling 13,904 m².
- Negotiations and Initial Proceedings
- November 17, 2006: TransCo offered to purchase Oroville’s lands for the Abaga–Kirahon 230 kV project; Oroville demanded rerouting and payment for the existing line. TransCo refused.
- April 20, 2007: Oroville filed a complaint for injunction and damages with prayer for temporary restraining order; TransCo answered May 9, 2007, and agreed to initiate expropriation.
- Expropriation Case Before the RTC
- Parties agreed to survey for just compensation; RTC suspended proceedings and directed TransCo to survey properties.
- Oroville moved to convert the complaint into expropriation proceedings and to require TransCo to pay BIR zonal values; TransCo raised no objection.
- May 17, 2010: RTC ordered TransCo to deposit a provisional P7,647,200.00 as just compensation; deposit released February 4, 2011; writ of possession issued March 21, 2011.
- August 8, 2011: RTC appointed three commissioners who submitted divergent valuations (P78.65/m², P1.20/m², and P2,000.00/m² inclusive of interest).
- RTC Decision and Court of Appeals Ruling
- December 12, 2012: RTC set aside commissioners’ reports, fixed just compensation at P1,520.00/m² from April 20, 2007 with 12% interest per annum, minus the provisional deposit.
- September 18, 2015: CA modified the RTC judgment, held the 1983 entry without color of legal authority so no taking occurred then, reckoned compensation from filing of complaint (2007), and ordered payment of P13,486,880.00 with interest (12% then reduced to 6%).
- January 25, 2016: CA denied TransCo’s motion for reconsideration. TransCo filed the present petition before the Supreme Court.
Issues:
- Whether just compensation must be based on the property’s fair market value at the time of taking (1983) or at the time of filing of the complaint (2007).
- Whether the imposition of 12% legal interest per annum is unjustified.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)