G.R. No. 245266 - National Transmission Corp. vs. Religious of the Virgin Mary

The petitioner, National Transmission Corporation (TransCo), and the respondent, Religious of the Virgin Mary (RVM), are involved in an expropriation dispute.
RVM owns a 360,029-square-meter parcel in Barrio Iponan, Cagayan de Oro City, covered by Original Certificate of Title No. 0-452.
The dispute centers on a portion of the respondent’s land (initially claimed at 17,185 square meters) allegedly occupied by transmission lines constructed by TransCo.

On October 25, 2006, RVM filed a complaint for just compensation and damages against TransCo, asserting that transmission lines were constructed without consent and without expropriation proceedings.
In its answer, TransCo admitted the presence of its transmission lines on a part of RVM’s property but contended that the affected area was less than alleged.
TransCo also asserted that it had acquired an easement by prescription, raising arguments on its continued right of use.

A February 26, 2007 regional order commissioned a survey by the Department of Environment and Natural Resources, which reported the transmission line occupying 8,721 square meters.
In subsequent filings and orders, the Regional Trial Court directed provisional deposits and later modified its orders:

An April 11, 2011 order directed TransCo to deposit P982,742.00 as provisional compensation.
TransCo corrected the order based on its claim of an affected area of 8,560 square meters, with a zonal value of P105 per square meter, leading to a revised amount of P898,800.00.
On May 18, 2012, the court granted TransCo’s motion, and a deposit of P898,000.00 was made.

TransCo’s nominated commissioner was Norberto Badelles, Jr.
RVM’s nominated commissioner was Engr. Romualdo Lagsa.
Atty. Noel Bacal was appointed as the chairperson to reconcile the valuation reports.

An affected area of approximately 8,580 square meters.
The transmission line’s construction in 1966 by the National Power Corporation (NAPOCOR) and the absence of a zonal valuation until 1994, recommending the use of the 1994 zonal value of P50.00 per square meter.

Commissioner Lagsa recommended a valuation of P700.00 per square meter, though without a detailed basis.
Chairperson Atty. Bacal noted:

Verification that the affected area is 8,721 square meters.
A transmission line commissioned in 1966.
A proposal to use the 2006 zonal value—which he considered close to the market value at the time—with a rate of P200.00 per square meter.

In a March 31, 2014 order, the Regional Trial Court approved Atty. Bacal’s recommendation and ordered TransCo to pay a total just compensation of P1,744,200.00, deducting the earlier deposit.
On March 31, 2017, the same court modified the interest rates applicable to the just compensation:

Interest was set at 12% per annum from October 25, 2006 to June 30, 2013.
Interest on the remaining balance was set at 6% per annum from July 1, 2013 until full payment.

TransCo appealed the basis of valuation (2006 values) to the Court of Appeals, arguing that compensation should be based on the 1966 date of taking.
The Court of Appeals, in its May 31, 2018 decision, remanded the case to the Regional Trial Court with instructions to determine just compensation based on the 2014 values. TransCo’s subsequent motion for reconsideration was denied.

TransCo filed the present petition challenging the Court of Appeals’ decision.
The central contention by TransCo was that just compensation must be reckoned from the time of actual taking (1966) rather than from 2014, when compensation found legal mooring.
The petition also argued that the precedent relied on by the Court of Appeals, primarily from Pidacan, was inapplicable given the unique circumstances of the case and the evidence supporting a 1966 taking.

Whether just compensation should be ascertained as of the date the property was taken (1966) or as of the later date (2014) when judicial proceedings affirmed the taking.
The impact of a dearth of evidence regarding valuations at the time of taking on the final determination.

Whether the precedent cases (e.g., Heirs of Pidacan, Oroville, and others) support taking the valuation as of the filing date or the actual date of taking.
The appropriateness of imposing interest to compensate for delays in payment of just compensation.

Whether TransCo’s admission of intrusion coupled with a claim of easement by prescription has any bearing on the necessity of payment of just compensation.

Whether the rules expressed in Rule 67 of the 1997 Rules of Civil Procedure, regarding the reckoning date for compensation, have been properly applied.
The extent to which procedural defaults or omissions (e.g., failing to allege a date of taking in the Answer or Pre-Trial Brief) affect the compensation basis.