Case Digest (G.R. No. 203039) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On February 12, 1998, the Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH), filed an expropriation suit in the Regional Trial Court (RTC) of Las Piñas City, Branch 275, seeking 281 square meters of land owned by the Bank of the Philippine Islands (BPI) (TCT No. T-59156) and 177 square meters owned by Bayani Villanueva (TCT No. T-64556) for the construction of the Zapote-Alabang Fly-Over. Neither BPI nor Villanueva contested the propriety of the taking, prompting the RTC to appoint a Board of Commissioners. On September 29, 1998, the Board valued the land at ₱40,000.00 per square meter. The RTC’s November 25, 1998 Decision awarded BPI ₱10,607,750.00 and Villanueva ₱4,425,000.00 after deducting deposits. On December 15, 1998, the Acting Clerk certified that the decision had become final and executory as of December 11, 1998. The following day, BPI filed a Motion for Partial New Trial to determine just compensation for its expropriated Case Digest (G.R. No. 203039) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Expropriation of Land
- On February 12, 1998, the Department of Public Works and Highways (DPWH) filed a petition for expropriation in RTC Las Piñas City, Branch 275, against portions of Bank of the Philippine Islands’ (BPI) lot (281 sqm under TCT T-59156) and Bayani Villanueva’s lot (177 sqm under TCT T-64556) for the Zapote-Alabang Fly-Over.
- Neither BPI nor Villanueva contested the expropriation; the court constituted a Board of Commissioners, which on September 29, 1998 recommended P40,000.00 per sqm as fair market value.
- On November 25, 1998, the trial court fixed just compensation at P40,000.00/sqm: P11,240,000.00 to BPI (281 sqm) and P7,080,000.00 to Villanueva (177 sqm), net of prior deposits, ordering DPWH to pay BPI P10,607,750.00 and Villanueva P4,425,000.00.
- On December 15, 1998, the clerk of court certified the November 25 Decision “final, executory and unappealable” as of December 11, 1998, noting the Solicitor General’s failure to appeal or move for reconsideration.
- Determination of Building Compensation
- On December 16, 1998, BPI moved for a partial new trial to include its building not covered in the November 25 Decision, claiming receipt of that Decision only on December 1, 1998.
- The trial court granted the motion on January 6, 1999; BPI presented evidence ex parte; an ocular inspection by court OIC Commissioner Agbayani on September 7, 1999 found a newly constructed building and improvements.
- On September 10, 1999, the trial court awarded BPI P2,633,000.00 for the building. On February 14, 2000, it set aside that award for procedural defects under Rule 67, §§ 5–8, and constituted a new Board of Commissioners.
- Petitioner objected, claiming the building was not taken; the court nonetheless ordered the nomination of commissioners. BPI and DPWH nominated their commissioners, who submitted competing valuations: P2,633,000.00 (BPI’s appraiser) and P1,905,600.00 (tax declaration).
- On February 3, 2003, the trial court adopted the lower valuation, ordering DPWH to pay P1,905,600.00. DPWH appealed to the Court of Appeals (CA-G.R. CV No. 79843).
- On September 14, 2011, the Court of Appeals affirmed, holding BPI’s motion timely (no proof of service, party admission of December 1 receipt), and that consequential damages for the building were proper even without actual taking. A February 3, 2012 motion for reconsideration was denied on August 6, 2012.
- DPWH filed this Rule 45 petition challenging: (a) finality of the November 25, 1998 Decision, and (b) the legal basis and amount of the additional just compensation for the building.
Issues:
- Whether the November 25, 1998 Decision had become final and executory before BPI filed its motion for partial new trial.
- Whether the award of additional just compensation in the amount of P1,905,600.00 for BPI’s building is unfounded and without legal basis.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)