Facts:

The case involves the National Transmission Corporation (TRANSCO) as the petitioner and spouses Mariano S. Taglao and Corazon M. Taglao as the respondents. The events leading to the case began on November 24, 1995, when the National Power Corporation (NPC), a government entity responsible for the development of hydroelectric power, filed a complaint for eminent domain against the Taglaos in the Regional Trial Court (RTC) of Tanauan City, Batangas. The NPC sought to acquire an easement of right of way over a 3,573-square meter portion of the Taglaos' property, which is a total of 5,143 square meters located in San Pioquinto, Malvar, Batangas. The Taglaos moved to dismiss the case, but the RTC denied their motion and granted the NPC a writ of possession on September 18, 1996. Subsequently, the RTC declared the property condemned on June 23, 1999, and directed both parties to submit their recommended commissioners to determine just compensation. The NPC's commissioner re...

Facts:

Background of the Case: The National Transmission Corporation (TRANSCO), as the transferee-in-interest of the National Power Corporation (NPC), filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court. The petition sought to nullify the Decision and Resolution of the Court of Appeals (CA) in CA-G.R. CV No. 102782, which dismissed NPC's appeal and affirmed the Regional Trial Court (RTC) Decision in favor of the Spouses Mariano and Corazon Taglao.

Purpose of NPC: NPC, a government entity, was created to develop hydroelectric power and produce electricity. It was authorized under Republic Act No. 6395 to acquire private properties for its projects.

Eminent Domain Case: On November 24, 1995, NPC filed a Complaint for Eminent Domain against the Spouses Taglao to acquire an easement of right of way over a 3,573-square-meter portion of their 5,143-square-meter property in San Pioquinto, Malvar, Batangas, for the Tayabas-Dasmariñas 500 KV Transmission Line Project.

RTC Proceedings:

• The RTC denied the Spouses Taglao's Motion to Dismiss and granted NPC's Motion for the Issuance of a Writ of Possession on September 18, 1996.
• On June 23, 1999, the RTC declared the subject property as condemned.
• The RTC directed the parties to submit the names of commissioners to determine just compensation. NPC recommended Engineer Moiselito C. Abcejo, while the Spouses Taglao recommended Atty. Elueterio G. Zaballero.

Commissioners' Reports:

• NPC's commissioner recommended P156,690.44 as just compensation, broken down into:
  • P4,490.44 as easement fee (10% of the fair market value based on Tax Declaration).
  • P151,570.00 as the value of damaged improvements.
  • P300.00 as tower occupancy fee for two legs.
• The Spouses Taglao's commissioner recommended P12,858,000.00 as just compensation, based on a market value of P2,500.00 per square meter as of August 15, 2000.

RTC Decision: The RTC fixed the market value of the subject property at P1,000.00 per square meter and computed just compensation at P509,170.00, applying the formula:

• Easement Fee = Market Value x Area Affected x 10% = P357,300.00
• Tower Occupancy Fee = P300.00
• Value of crops/plants/trees/improvements = P151,570.00
• Total = P509,170.00

NPC's Motion for Reconsideration was denied on August 8, 2007.

CA Decision: The CA affirmed the RTC's Decision, stating that the P1,000.00 per square meter valuation was reasonable, given that the property's value in 2000 was between P2,000.00 to P2,500.00 per square meter.

Issue:

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Ruling:

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Ratio:

1. Just Compensation:

   • Just compensation is the full and fair equivalent of the property taken from its owner. It must be based on the fair market value of the property at the time of the filing of the complaint or the taking of the property, whichever comes first.
   • The valuation must consider relevant factors such as the cost of acquisition, current value of like properties, size, shape, location, and tax declarations.

2. Easement of Right of Way:

   • An easement of right of way, even if it does not involve the transfer of ownership, still deprives the owner of the normal use of the property. Therefore, the owner is entitled to just compensation equivalent to the monetary value of the land taken.

3. Speculative Valuations:

   • Courts cannot base their valuations on speculation or conjecture. The determination of just compensation must be grounded on established rules, principles, and competent evidence.

4. Interest on Unpaid Compensation:

   • Legal interest on unpaid just compensation is applicable to ensure that the owner is fully compensated for the loss of the property's use from the time of taking until full payment.