Case Digest (G.R. No. 79732) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines v. Court of Appeals, Henrico Uvero and others owned parcels of land affected by the Nabua-Bato-Agos Section improvement project under the Philippine-Japan Highway Loan. On August 2, 1988, the Republic filed expropriation proceedings in the Regional Trial Court (RTC) seeking to widen and concrete the highway, offering compensation based on Presidential Decree No. 76, as amended, which calculates payment on the lower of the assessor’s valuation or the owner’s declared valuation. The private respondents resisted, insisting on the fair market value as just compensation. The RTC ruled in favor of the respondents, and the Court of Appeals affirmed that decision. The Republic then petitioned this Court via G.R. No. 79732, arguing that its right to take the property was undisputed and asking whether the declaration of Presidential Decree No. 1533 as unconstitutional in Export Processing Zone Authority (EPZA) vs. Dulay should apply to their case, particular Case Digest (G.R. No. 79732) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the case
- The Republic of the Philippines filed an expropriation proceeding to acquire portions of land owned by Henrico Uvero and others for widening and concreting the Nabua–Bato–Agos section of the Philippine–Japan Highway Loan road.
- Respondents conceded the Republic’s right of eminent domain but challenged the basis of just compensation, insisting on fair market value rather than the lesser of assessor’s valuation or owner’s declared valuation as fixed by Presidential Decree No. 76, as amended (and mirrored in PD 1533).
- Procedural history
- The Regional Trial Court ruled in favor of the private respondents, adopting fair market value as the measure of compensation.
- The Court of Appeals affirmed the trial court’s decision.
- The Republic elevated the case to the Supreme Court by petition for review, despite this Court’s prior ruling in EPZA v. Dulay (G.R. No. 59603, April 29, 1987) declaring PD 76 and related decrees unconstitutional for assigning to the executive branch a judicial function in determining just compensation.
Issues:
- What is the effect of the Supreme Court’s declaration that PD 1533 is unconstitutional and void, and should that declaration apply retrospectively to cases pending on appeal where PD 1533’s constitutionality was not previously questioned?
- Whether this Court’s decision in EPZA v. Dulay, declaring PD 1533 unconstitutional, must be applied in the present expropriation proceedings.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)