G.R. No. 157847 - Republic vs. Sarabia

The subject property is a 4,901 square-meter portion of Lot 6068, a 10,468 square-meter lot located at Pook, Kalibo, Aklan, covered by Original Certificate of Title No. P-15596 in the names of the heirs of the late Segundo De la Cruz.
In 1956, the Air Transportation Office (ATO) took possession and control of the 4,901 square-meter portion of Lot 6068.
Initially, the area was utilized as an airport parking space, but over time, various structures were erected on it, including a control tower, Kalibo crash fire rescue station, airport terminal, and the headquarters of the PNP Aviation Security Group.

In 1995, construction of stores and restaurants made of light materials occurred on the area outside the 4,901 square-meter portion.
In 1997, private respondents filed a complaint for Recovery of Possession with Damages before the Municipal Trial Court of Kalibo, in which the ATO intervened by asserting that the occupants were its lessees.
The petitioner (Republic of the Philippines, represented by the ATO) assured the respondents that they would be paid the fair market value for the subject land; however, the parties failed to agree on the compensation amount.

On June 25, 1998, the petitioner filed an expropriation suit for the entire Lot 6068 with the Regional Trial Court at Aklan (Civil Case No. 5543).
On August 6, 1999, three commissioners were appointed by the trial court to determine the just compensation for the property.
The commissioners’ report recommended fixing the value at P800.00 per square meter for the 4,901 square-meter portion (Lot 6068-A) and P500.00 per square meter for the remaining 5,567 square-meter portion (Lot 6068-B).

During the pre-trial and subsequent hearings, the petitioner was directed to prove that the unoccupied portion was needed for public use. The petitioner argued that since almost half of the property was already used for public purposes, evidence for the unoccupied area was unnecessary.
The trial court ultimately ruled that only the 4,901 square-meter portion (Lot 6068-A) was necessary for public use.
The trial court adopted the commissioners’ report and fixed the just compensation for Lot 6068-A at the market value of P800.00 per square meter based on a determination dated November 11, 1999, the date of issuance of the writ of possession.

Dissatisfied with the trial court's ruling, the petitioner appealed; the case was transmitted to the Court of Appeals where the decision (dated November 18, 2002) affirmed the trial court’s ruling.
The appellate decision emphasized that despite evidence of possession since 1956, the characterization of “taking” should consider the legal right to possess as of the issuance of the writ of possession in 1999.
The petitioner later moved for reconsideration before filing a petition for review on certiorari under Rule 45, which ultimately led to the present Supreme Court decision.

Whether the just compensation should be determined based on the market value of the property in 1956, when the ATO initially took physical possession, or as of November 11, 1999, the date of the issuance of the writ of possession.
How the determination of “taking” affects the rights of the petitioner and the computation of compensation.

Whether the evidence presented by the petitioner is sufficient to demonstrate that the actual taking of the property occurred in 1956.
The impact of admissions by the respondents in their Answer and Pre-Trial Brief regarding long-standing possession, and whether these admissions render the taking conclusively established.

The extent to which previous Supreme Court cases (e.g., Republic vs. Lara; Jose Ma. Ansaldo vs. Francisco S. Tantuico, Jr. and Baltazar Aquino) dictate the proper basis for fixing just compensation.
Whether the proper date for assessing the market value of the property should be aligned with the time of taking or the initiation of expropriation proceedings.