Case Digest (G.R. No. 224936) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In PNOC Alternative Fuels Corporation v. National Grid Corporation of the Philippines, respondent NGCP filed a Complaint for Expropriation on February 9, 2011 before the Regional Trial Court of Mariveles, Bataan, Branch 4, seeking to condemn 101,290.42 square meters of land in Barangays Batangas II and Lamao, Bataan, to construct the Mariveles-Limay 230 kV Transmission Line. The parcel, part of the Petrochemical Industrial Park, was originally public domain reserved under Executive Order No. 48 (1919), later reclassified and managed by PNOC through P.P. Nos. 361 (1968) and 630 (1969), P.D. No. 949 (1976), and P.D. No. 1803 (1981), then vested in petitioner PAFC, a PNOC subsidiary renamed in 2006. NGCP invoked its eminent domain power under Section 4 of R.A. No. 9511. PAFC and Orica Philippines, Inc., a lessee in the park, opposed, arguing the land was devoted to a public purpose and hence invulnerable to private expropriation. On February 11, 2016, the RTC issued an Order of Exp Case Digest (G.R. No. 224936) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Case Origin
- National Grid Corporation of the Philippines (NGCP), a private corporation with a legislative franchise under Republic Act No. 9511 to construct and maintain the national high-voltage transmission grid, filed a Complaint for Expropriation on February 9, 2011 against PNOC Alternative Fuels Corporation (PAFC; formerly PNOC Petrochemicals Development Corporation), Orica Philippines, Inc., and other respondents for a 101,290.42 sq. m. parcel in Barangay Batangas II, Mariveles and Barangay Lamao, Limay, Bataan.
- NGCP alleged failed negotiations with PAFC, invoked its delegated right of eminent domain under Section 4, R.A. 9511, to acquire the property for its Mariveles-Limay 230 kV Transmission Line Project.
- Subject Property’s History and Status
- Originally part of the public domain reserved for horticultural experiments under Executive Order No. 48 (1919), the parcel was withdrawn and declared an industrial reservation by Presidential Proclamation No. 361 (1968), amended and enlarged by P.P. 630 (1969).
- Presidential Decree No. 949 (1976), as amended by P.D. 1803 (1981), transferred administration to PNOC for development as a petrochemical industrial zone; R.A. 10516 (2013) further expanded permitted uses to energy and energy-allied activities.
- DOE Circular DC2013-06-0011 (2013 IRR) confirmed PAFC’s ownership per a 1994 Deed of Assignment and mandated proprietary management and development of the industrial estate.
- Trial Court Proceedings
- RTC of Mariveles, Bataan, Branch 4 issued the Assailed Order of Expropriation on February 11, 2016, denying PAFC’s and Orica’s defenses, declaring NGCP’s right to expropriate, and directing the appointment of commissioners to determine just compensation.
- PAFC’s Motion for Reconsideration was denied on April 18, 2016. PAFC filed a Petition for Certiorari under Rule 45 (though styled incorrectly) directly before the Supreme Court to annul the expropriation order.
Issues:
- Procedural Issue
- Whether PAFC’s direct petition under Rule 45 is proper or whether an appeal should have been elevated to the Court of Appeals via notice or record on appeal.
- Substantive Issue
- Whether the RTC correctly determined that NGCP, under Section 4 of R.A. 9511, had the authority to expropriate the subject property.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)