Title
Republic vs. Spouses Silvestre
Case
G.R. No. 237324
Decision Date
Feb 6, 2019
The Republic expropriated land in Valenzuela City for a road project, disputed ownership and valuation arose, and the Supreme Court upheld P5,000/sq.m. as just compensation, affirming CA's decision.
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Case Digest (G.R. No. 237324)

Facts:

  1. Expropriation of Property: The Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH), filed an expropriation case under Republic Act (R.A.) No. 8974 to acquire a 3,856-square meter lot in Barangay Ugong, Valenzuela City, for the construction of the C-5 Northern Link Project, Segment 8.1. The project aimed to improve travel efficiency between Mindanao Avenue in Quezon City and the North Luzon Expressway in Valenzuela City.
  2. Unknown Owner: Initially, the owner of the property was unknown and designated as "QQQQ." The RTC issued a writ of possession after the Republic-DPWH deposited P4,627,200.00, representing 100% of the property's zonal value.
  3. Discovery of Additional Owners: It was later discovered that an 811-square meter portion of the property was owned by Spouses Quintin Galguierra, et al. The Republic-DPWH amended its complaint to include them as defendants and deposited P973,200.00, the zonal value of their portion.
  4. Claim by Spouses Silvestre and Natividad Gozo: Respondents Spouses Aurora and Rogelio Silvestre and Natividad Gozo claimed ownership of a 6,629-square meter lot, of which 4,367 square meters were allegedly affected by the expropriation. They demanded P9,389,050.00 as just compensation.
  5. Dispute Over Area and Valuation: The Republic-DPWH contested the area claimed by Silvestre, et al., asserting that only 3,045 square meters were affected, with a zonal value of P1,200.00 per square meter. The RTC appointed a Board of Commissioners (BOC) to determine just compensation.
  6. BOC Recommendation: The BOC recommended P5,000.00 per square meter as just compensation, considering factors such as the property's size, location, accessibility, and comparable sales in the area.
  7. RTC and CA Decisions: The RTC adopted the BOC's recommendation but limited the affected area to 3,045 square meters, fixing just compensation at P15,225,000.00. The CA affirmed the RTC's decision but modified the interest rates on the unpaid balance.

Issue:

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Ruling:

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Ratio:

  1. Just Compensation: Just compensation is the full and fair equivalent of the property taken from the owner. It is not based on the taker's gain but on the owner's loss. The determination of just compensation is a judicial prerogative, but the appointment of commissioners is mandatory to ensure a fair valuation.
  2. Factors for Valuation: The BOC's recommendation was based on statutory guidelines under Section 5 of R.A. No. 8974, including the property's classification, developmental costs, current selling prices of similar lands, and other relevant factors. The Court found no arbitrariness in the BOC's recommendation of P5,000.00 per square meter.
  3. Zonal Valuation and Tax Declaration: While zonal valuation and tax declarations are relevant, they are not the sole basis for determining just compensation. The BOC's comprehensive evaluation of the property's characteristics and comparable sales justified the higher valuation.
  4. Legal Interest: The Court upheld the CA's imposition of legal interest on the unpaid balance of just compensation. Interest accrues at 12% per annum from the date of taking (May 5, 2008) until June 30, 2013, and at 6% per annum from July 1, 2013, until full payment.
  5. Commissioner's Fees and Attorney's Fees: The CA correctly deleted the award of commissioner's fees and attorney's fees for lack of factual and legal basis.


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