Case Digest (G.R. No. 120961)
Facts:
In Republic of the Philippines, represented by the National Irrigation Administration (NIA) v. Rural Bank of Kabacan, Inc. et al., G.R. No. 185124, decided January 25, 2012 under the 1987 Constitution, NIA sought to expropriate portions of three contiguous parcels totaling 14,497.91 m² in Kabacan, Cotabato for the Malitubog-Marigarao Irrigation Project. Lot No. 3080 (TCT No. T-61963) was registered in the name of the Rural Bank of Kabacan; Lot No. 455 (TCT No. T-74516) in the names of the Lao siblings; and Lot No. 3039 in the name of Littie Sarah Agdeppa, later amended to include Leosa Nanette Agdeppa and Marcelino Viernes. After NIA filed its complaint on September 8, 1994 (with two subsequent amendments adding respondents and specifying areas), respondents disputed NIA’s authority, necessity of expropriation, accuracy of valuation, and alleged non-negotiation and damages. On September 11, 1996, the RTC of Kabacan, Branch 22, appointed a commissioners’ committee under Rule 67 oCase Digest (G.R. No. 120961)
Facts:
- Background and Authority of NIA
- The National Irrigation Administration (NIA) was created under R.A. 3601 (1963) and amended by P.D. 552 (1974) and P.D. 1702 (1980), expressly empowered to exercise eminent domain.
- NIA filed on September 8, 1994, before RTC-Branch 22 in Kabacan, Cotabato, a Complaint for expropriation of portions of three parcels totaling 14,497.91 sqm for the Malitubog-Marigidao Irrigation Project.
- Parties and Affected Parcels
- Lot No. 3080 (TCT No. T-61963) – registered in the name of Rural Bank of Kabacan, Inc.
- Lot No. 455 (TCT No. T-74516) – registered in the names of R.G. May, Ronald Lao, and Rolando Lao.
- Lot No. 3039 – initially registered to Littie Sarah Agdeppa; amended to include Leosa Nanette A. Agdeppa and Marcelino Viernes.
- Trial Proceedings and Committee Reports
- Amended Complaints (July & September 1995) refined parties, areas, and requested immediate possession upon deposit of P19,246.58 as provisional value.
- Respondents filed Answers with defenses and counterclaims challenging NIA’s authority, necessity of expropriation, ownership of Lot 3080, and valuation of land and improvements (October 1995).
- On September 11, 1996, RTC formed a three-member committee (Clerk of Court, one member from each party) to assess fair market value; first report (October 1996) noted areas, age and number of trees, but commissioners disagreed on valuation.
- RTC appointed independent commissioners (October 22, 1996); their November 25, 1996 report valued land at P65/sqm (BIR zonal) and improvements (gmelina trees, coco trees, banana clumps).
- A December 3, 1997 supplemental report added value of earthfill excavated from Lots 3080 and 3039; NIA objected to including soil value.
- Trial Court Judgment (August 31, 1999)
- Adopted commissioners’ findings: expropriated 18,930 sqm; just compensation P1,230,450 for land; specific amounts for improvements and earthfill (P5,128,375.50 to Lot 3080 owners; P1,929,611.30 to Lot 3039 owners).
- Ordered NIA to pay improvements and earthfill to respective owners/intervenors and to deliver payments for the Rural Bank’s land to those who acquired it.
- Court of Appeals Decision (August 12, 2008)
- Affirmed the committee’s proper valuation process and adoption of fair market value for land and improvements.
- Deleted compensation for excavated soil, holding soil integral to land value at taking.
- Upheld award of compensation for Lot 3080 to intervenors (Margarita Tabaoda and Portia Ortiz) based on the Rural Bank’s non-participation and manifest abandonment of ownership.
- Denied NIA’s Motion for Reconsideration (October 22 & November 2008).
- NIA filed Petition for Review on Certiorari under Rule 45 before the Supreme Court.
Issues:
- Whether the Court of Appeals erred in affirming the trial court’s adoption of the commissioners’ report as basis for just compensation for land and improvements.
- Whether the Court of Appeals erred in ruling that compensation for Lot No. 3080, still registered in the Rural Bank’s name, should be paid to intervenors Margarita Tabaoda and Portia Ortiz.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)