Facts:

• On February 12, 2013, the Republic of the Philippines, through the Department of Public Works and Highways (DPWH), filed an expropriation complaint against Belly H. Ng, represented by Annabelle G. Wong, in the Regional Trial Court (RTC) of Valenzuela City, Branch 270.
• The complaint aimed to expropriate two lots registered under Transfer Certificate of Title (TCT) Nos. V-92188 and V-92191, totaling 1,671 square meters, along with improvements covering 2,121.7 square meters, located in Kowloon Industrial Compound, Tatalon Street, Brgy. Ugong, Valenzuela City.
• The expropriation was for the Mindanao Avenue Extension Project, Stage II-C, connecting Valenzuela City to Caloocan City.
• DPWH offered compensation of P6,684,000.00 for the land and P11,138,362.74 for the improvements, which Ng considered unreasonably low, asserting a fair market value of P25,000.00 per square meter for the land and P22,276,724.00 for the improvements.
• The RTC granted a Writ of Possession, and Ng received P17,822,362.74, representing the zonal value of the properties.
• A board of commissioners was appointed to determine just compensation, recommending P7,000.00 per square meter for the land and P12,000.00 per square meter for the improvements, with six percent legal interest.
• Ng objected to the land valuation, citing a previous case valuing similar properties at P15,000.00 per square meter.
• On November 26, 2013, the RTC fixed just compensation at P15,000.00 per square meter for the land and P12,000.00 per square meter for the improvements, awarding twelve percent legal interest and consequential damages.
• DPWH's motion for reconsideration was denied, leading to an appeal to the Court of Appeals (CA), which affirmed the RTC's decision on July 1, 2016, but deleted the award of consequential damages and reduced the legal interest to six percent.
• DPWH subsequently filed a petition for review on certiorari.

Issue:

• (Unlock)

Ruling:

• The Supreme Court partly granted the petition.
• It affirmed the just compensation for the lots at P15,000.00 per square meter but set aside the valuation of P12,000.00 per square meter for the improvements.
• The case was remanded to the RTC for further evidence on just compensation for the improvements.
• The legal interest was corrected to tw...(Unlock)

Ratio:

• The Supreme Court highlighted that the determination of just compensation in expropriation cases is governed by Republic Act No. 8974 and its implementing rules.
• The replacement cost met...continue reading