Case Digest (G.R. No. 223195)
Facts:
- The case involves the National Transmission Corporation (TRANSCO), the transferee-in-interest of the National Power Corporation (NPC), and the respondents, Spouses Mariano S. Taglao and Corazon M. Taglao.
- On November 24, 1995, the NPC filed a Complaint for Eminent Domain before the Regional Trial Court (RTC) of Tanauan City, Batangas, seeking to acquire an easement of right of way over a 3,573-square meter portion of the Spouses Taglao's 5,143-square meter property located in San Pioquinto, Malvar, Batangas.
- The NPC needed the property for its Tayabas-Dasmariñas 500 KV Transmission Line Project.
- The Spouses Taglao moved to dismiss the case, but the RTC denied their motion and granted the NPC's request for a Writ of Possession on September 18, 1996.
- The RTC later declared the property condemned on June 23, 1999, and directed the parties to submit names of recommended commissioners to determine just compensation.
- The NPC's commissioner recommended P156,690.44, while the Spouses Taglao's commissioner recommended P12,858,000.00.
- The RTC, in its January 13, 2003 decision, fixed the market value at P1,000.00 per square meter and computed just compensation at P509,170.00.
- The NPC's motion for reconsideration was denied on August 8, 2007.
- The Court of Appeals (CA) affirmed the RTC's decision on December 17, 2015, and denied the NPC's motion for reconsideration on February 22, 2016.
- TRANSCO then filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
Issue:
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Ruling:
- The Supreme Court ruled that just compensation should be determined based on the market value of the property at the time of the filing of the complaint, which was November 24, 1995.
- The Supreme Court found that the RTC and CA's valuation of P1,000.00 per square meter was speculative ...(Unlock)
Ratio:
- The Supreme Court emphasized that just compensation is the full and fair equivalent of the property taken from its owner by the expropriator, and it should be based on the fair market value at the time of the filing of the complaint or the taking, whichever comes first.
- In this case, the filing of the complaint on November 24, 1995, preceded the taking.
- The Court found that the valuations provided by the commissioners were not reflective of the market value at the relevant time.
- The RTC's valuation of P1,000.00 per square meter was also unsu...continue reading
Case Digest (G.R. No. 223195)
Facts:
The case involves the National Transmission Corporation (TRANSCO), the transferee-in-interest of the National Power Corporation (NPC), and the respondents, Spouses Mariano S. Taglao and Corazon M. Taglao. On November 24, 1995, the NPC filed a Complaint for Eminent Domain before the Regional Trial Court (RTC) of Tanauan City, Batangas, seeking to acquire an easement of right of way over a 3,573-square meter portion of the Spouses Taglao's 5,143-square meter property located in San Pioquinto, Malvar, Batangas. The NPC needed the property for its Tayabas-Dasmariñas 500 KV Transmission Line Project. The Spouses Taglao moved to dismiss the case, but the RTC denied their motion and granted the NPC's request for a Writ of Possession on September 18, 1996. The RTC later declared the property condemned on June 23, 1999, and directed the parties to submit names of recommended commissioners to determine just compensation. The NPC's commissioner recommended P156,690.44, while the Spouses Taglao's commissioner recommended P12,858,000.00. The RTC, in its January 13, 2003 decision, fixed the market value at P1,000.00 per square meter and computed just compensation at P509,170.00. The NPC's motion for reconsideration was denied on August 8, 2007. The Court of Appeals (CA) affirmed the RTC's decision on December 17, 2015, and denied the NPC's motion for reconsideration on February 22, 2016. TRANSCO then filed a Pet...