Case Digest (G.R. No. 222551)
Facts:
On December 7, 2007, Republic of the Philippines, as represented by the Department of Public Works and Highways filed a complaint for expropriation against Spouses Pedro and Zenaida Goloyuco for a 50-square-meter lot in Barangay Ugong, Valenzuela City for the C-5 Northern Link Road Project; petitioner deposited DBP Manager's Check No. 615039 in the amount of P137,500.00 and took possession by writ on September 24, 2008. The RTC, after commissioners' reports, fixed just compensation at P8,300.00 per square meter in a February 18, 2014 Decision; the Court of Appeals affirmed with modification as to interest on July 21, 2015 and denied reconsideration on January 12, 2016, prompting this petition for review on certiorari.Issues:
- Did the Court of Appeals err in upholding the trial court's fixation of just compensation at P8,300.00 per square meter for the subject property?
Ruling:
The petition was denied for lack of merit and the Court of Appeals' Decision and Resolution were Case Digest (G.R. No. 222551)
Facts:
- Case title, parties, and nature of action
- Republic of the Philippines, as represented by the Department of Public Works and Highways (petitioner) filed a complaint for expropriation against Spouses Pedro and Zenaida Goloyuco (respondents) on December 7, 2007, before the Regional Trial Court (RTC), Valenzuela City, Branch 172.
- The subject property is a 50-square meter lot located in Barangay Ugong, Valenzuela City, sought to be expropriated for the construction of the C-5 Northern Link Road Project, Segment 8.1.
- Preliminary proceedings, possession, and provisional deposit
- Petitioner filed an Urgent Ex Parte Motion for Issuance of Writ of Possession on February 29, 2009.
- The RTC ordered petitioner to issue a check to the spouses Goloyuco for P137,500.00 representing the zonal valuation of the subject property.
- On September 19, 2008, the spouses Goloyuco received DBP Manager's Check No. 615039 dated September 16, 2008 in the amount of P137,500.00.
- The RTC issued the writ of possession and order of expropriation on September 24, 2008.
- Commissioners' reports on just compensation
- The RTC appointed three commissioners to determine just compensation.
- Commissioner Cecilynne R. Andrade recommended P12,250.00 per sq m as just compensation.
- Commissioners Engr. Romeo S. Selva and Osita F. De Guzman recommended P10,000.00 per sq m as just compensation.
- Trial court (RTC) decision
- In a Decision dated February 18, 2014, the RTC classified the subject property as residential with a BIR zonal valuation of P2,750.00 per sq m.
- The RTC observed the lot's rectangular shape, generally flat terrain, and vicinity to residential and some industrial properties in Barangay Ugong, Valenzuela City; and noted Valenzuela City as a high intensity commercial zone.
- The RTC considered commissioners' reports and prior expropriation awards involving the same project (cases of Mapalad, Hobart, Garcia, Liao Chin Guat Balisbis and Edna Lim) and fixed just compensation at P8,300.00 per sq m, totaling P415,000.00 for 50 sq m.
- The RTC deducted the provisional deposit of P137,500.00 and ordered petitioner to pay interest at 12% per annum on the unpaid balance of P277,500.00 from the time of taking until full payment; assigned payment of capital gains tax to the defendants and transfer tax and related fees to the plaintiff.
- Court of Appeals proceedings and ruling
- Petitioner appealed to the Court of Appeals (CA), which issued a Decision dated July 21, 2015 affirming with modification the RTC decision.
- The CA held that the RTC made an independent assessment considering BIR zonal valuation and commissioners' reports and applied factors under Section 5 of R.A. No. 8974.
- The CA modified the interest reckoning and ruled that legal interest of 12% shall run from December 7, 2007 until June 30, 2013, and from July 1, 2013 unt...(Subscriber-Only)
Issues:
- Primary legal question presented to the Supreme Court
- Whether the Court of Appeals erred in upholding the RTC's fixation of just compensation at P8,300.00 per square meter for the subject property.
- Subsidiary factual and legal contentions raised by the parties
- Petitioner’s contention: the BIR zonal valuation of P2,750.00 per sq m should govern the appraisal and just compensation; reliance on higher awards constitutes unfairness and potential unjust enrichment and conflicts with tax assessments.
- Respondents’ contention: prevailing selling prices and commissioners' reports justify a valuation su...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)