Case Digest (G.R. No. 192100)
Facts:
In Republic of the Philippines, represented by the Department of Public Works and Highways (formerly the Toll Regulatory Board), v. Asia Pacific Integrated Steel Corporation (G.R. No. 192100, March 12, 2014), the Republic sought to expropriate a 2,024-square-meter portion of respondent’s 17,175-square-meter property in Barangay Sta. Monica, San Simon, Pampanga, for the North Luzon Expressway expansion. On March 1, 2002, the Republic filed expropriation proceedings under Republic Act No. 8974 and deposited ₱607,200.00 (100% of the BIR zonal valuation) with the Land Bank of the Philippines, moving for an ex parte writ of possession. On March 19, 2002, the Regional Trial Court (Branch 54, Macabebe, Pampanga) granted possession. Respondent contested only the amount of just compensation. The parties agreed to submit valuation to three court-appointed commissioners, who recommended ₱1,000–₱1,500 per square meter based on opinion values of brokers, bankers, and an industrial land conveCase Digest (G.R. No. 192100)
Facts:
- Background and Parties
- Asia Pacific Integrated Steel Corporation (respondent) owns a 17,175-sqm property in Sta. Monica, San Simon, Pampanga (TCT No. 271813-R).
- Republic of the Philippines (petitioner), through the Toll Regulatory Board (TRB), instituted expropriation on March 1, 2002 over 2,024 sqm for the San Simon Interchange of the NLEX Project.
- Trial Court Proceedings
- Petitioner filed an ex parte motion for writ of possession, depositing ₱607,200.00 (100% of BIR zonal value) with LBP; RTC granted possession on March 19, 2002.
- Respondent contested TRB’s authority and offered compensation, arguing just compensation was ₱1,500/sqm (₱3,036,000.00) based on fair market value.
- Parties agreed to submit valuation to three commissioners (Municipal Assessor as Chair, Clerk of Court, Register of Deeds).
- On June 9, 2004, commissioners reported opinion values of ₱1,000–1,500/sqm for industrial land, citing conversion order.
- Ocular inspection on September 23, 2004 noted a toll plaza, exact area of taking (2,021 sqm), swampy adjacent remnant.
- RTC found ₱1,300/sqm fair, awarded ₱2,024,000.00 less deposit, plus 12% legal interest from March 21, 2002, costs, and cleared encumbrances.
- Appellate History
- Court of Appeals (July 21, 2009) affirmed RTC’s valuation but reduced interest to 6% per annum; denied reconsideration (April 28, 2010).
- Petitioner filed Rule 45 petition in the Supreme Court, claiming improper valuation methodology and excessive award.
Issues:
- Primary Legal Questions
- Whether the RTC based its determination of just compensation on the factors enumerated in Section 5 of R.A. 8974.
- Whether reliance on an unsubstantiated commissioners’ report without documentary evidence complies with the law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)