Case Digest (G.R. No. 192100)
Facts:
Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH) v. Asia Pacific Integrated Steel Corporation, G.R. No. 192100, March 12, 2014, Supreme Court First Division, Villarama, Jr., J., writing for the Court.
Asia Pacific Integrated Steel Corporation (respondent) owned a 17,175-square-meter parcel in San Simon, Pampanga (TCT No. 271813‑R). On March 1, 2002 the Toll Regulatory Board (TRB) instituted expropriation proceedings over a 2,024-square-meter portion for the NLEX expansion and deposited P607,200.00 (based on BIR zonal valuation) with the Land Bank of the Philippines, prompting the trial court to issue a writ of possession on March 19, 2002 pursuant to Republic Act No. 8974 and Rule 67 procedures.
Respondent contested the TRB’s authority and the amount of compensation; during pre-trial the parties agreed TRB could expropriate but disagreed on just compensation. They submitted valuation to three commissioners (Municipal Assessor as Chair, Branch Clerk of Court, Register of Deeds). The commissioners’ Report recommended opinion values for industrial lands of P1,000–P1,500 per sqm based largely on appraisers’ and realtors’ opinions rather than documentary sales evidence. The trial court conducted an ocular inspection on September 23, 2004 and found the expropriated portion and site conditions.
In a September 21, 2007 decision, the Regional Trial Court (RTC), Branch 54, Macabebe, Pampanga accepted the commissioners’ report as a guide and fixed just compensation at P1,300 per sqm (total net P2,024,000 after crediting the partial deposit), and awarded legal interest of 12% per annum from the time of taking, plus costs related to transfer. Petitioner appealed.
The Court of Appeals (CA) in a July 21, 2009 decision (CA‑G.R. CV No. 90539) affirmed the RTC’s determination of just compensation but reduced legal interest to 6% per annum, holding that BIR zonal valuation is only a guide and that fair market value governs. The CA denied peti...(Pro-only)
Issues:
- Under Rule 45, is the question presented — whether the trial court properly determined just compensation in conformity with Section 5 of R.A. 8974 — a question of law reviewable by this Court?
- Did the trial court properly determine just compensation for the expropriated portion by applying the standards in Section 5 of R.A. 8974 and established jurisprudence, or must its valuation be set aside for ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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