G.R. No. 191805 - Rodriguez vs. Macapagal-Arroyo

The case involves consolidated petitions for review on certiorari arising from the decision of the Court of Appeals.
Petitioners include members of the Rebadulla family (Paz E. Rebadulla, Perrain E. Rebadulla, Jocelyn E. Rebadulla, Clevis E. Rebadulla, Hazel R. Riguera, Ariel E. Rebadulla, Giovanni Clyde E. Rebadulla, Roel E. Sta. Maria, Kleiner Kyle R. Sta. Maria, and Kerschel R. Sta. Maria) and, by substitution, the heirs of Paz R. Sta. Maria.
Respondents and opposing parties include the Republic of the Philippines, the Secretary of Public Works and Highways (DPWH), and Engr. Tomas L. Buen, Project Manager, DPWH-PMO-SWIM Project.

On March 17, 1997, the DPWH took parcels of land owned by the Rebadullas for its Small Water Impounding Management (SWIM) Project in Macagtas, Catarman, Northern Samar.
The initial valuation offered by the DPWH was based on a Provincial Appraisal Committee (PAC) resolution dating from 1994 which set a value of P2.50 per square meter.
The Rebadullas rejected the DPWH offer and, in subsequent correspondence, claimed that the fair market value of the property was P200.00 per square meter.

In 1998, the Rebadullas formally requested a reappraisal of their property and reiterated their valuation.
Engr. Tomas L. Buen sought a reappraisal from the PAC in 1999 but was denied by the committee.
The parties sought assistance from the Department of Finance-Bureau of Local Government Finance (DOF-BLGF) in 2000, which eventually recommended reappraisal, although the Provincial Assessor failed to act.
By April 25, 2001, the DOF-BLGF communicated that their recommended reappraisal (benchmark value of P100.00 per sq m) was not accepted by the PAC, advising the Rebadullas to pursue judicial remedies.

On October 15, 2002, through counsel, the Rebadullas issued a final demand for compensation amounting to P33,010,800.00, based on their valuation of P200.00 per square meter for a total area of 165,054 sq m, as documented by title certificates.
The complaint filed before the Regional Trial Court (RTC) sought mandamus and damages to have the government pay just compensation based on the fair market value determined by the court.
In the complaint, the Rebadullas also prayed for:

Payment of legal interest at a rate of 6% per annum from the taking until full payment.
Recovery of moral and exemplary damages against Engr. Buen.
Attorney’s fees.

The RTC ruled that only the recovery of just compensation was viable given that the properties had already been used (dams constructed) and the Rebadullas had rejected the earlier offer.

The RTC rendered a decision on December 23, 2013, fixing just compensation at a rate based on the Bureau of Internal Revenue’s zonal valuation of P7.00 per square meter, legal interest at 6% per annum, and awarding attorney’s fees.
The CA, on February 24, 2015, affirmed the RTC decision with modifications by:

The CA also clarified the measurement of the property taken (154,521.49 sq m of the 165,054 sq m indicated by documents).
Motions for reconsideration by both parties were denied in later proceedings, with the CA’s latest resolution on January 7, 2016.

Whether the case, though styled as one for mandamus and damages, essentially constitutes an action for the recovery of just compensation due to the taking of private property for public use.
Whether, given the circumstances, mandamus is an appropriate remedy for compelling the payment of just compensation even when expropriation proceedings were not instituted.

Whether the RTC and subsequently the CA erred in relying predominantly on the Bureau of Internal Revenue’s zonal valuation of P7.00 per square meter as the sole index for determining just compensation.
Whether the Rebadullas’ submitted appraisal and claim of higher valuations (e.g., P95.00 or P200.00 per sq m) warranted further consideration given that it was not fully supported by documentary evidence.

Whether the determination that only 154,521.49 sq m of the total 165,054 sq m were taken by the Government was correct.
The evidentiary dispute regarding the exact area affected by the DPWH’s SWIM Project.

Whether interest should be computed from the date of the filing of the complaint or from the actual date of taking (March 17, 1997).
The propriety of increasing the interest rate to 12% per annum for the period before July 1, 2013, and its subsequent reduction to 6% per annum.
Whether the interest on the unpaid compensation should itself earn interest as provided by law.

Whether awarding attorney’s fees is justified given the absence of evidence showing gross negligence, bad faith, or malice on the part of government officers.
The issue of moral and exemplary damages against Engr. Buen in light of the Rebadullas’ repeated claims and government’s actions.