Case Digest (G.R. No. 242731)
Facts:
In Republic of the Philippines vs. Carmen M. Vda. de Castellvi, et al. (G.R. No. L-20620, August 15, 1974), the Republic filed on June 26, 1959 a complaint for eminent domain in the Court of First Instance of Pampanga (Civil Case No. 1623) to expropriate three parcels of land in Barrio San Jose, Floridablanca, Pampanga: Lot No. 199-B (759,299 sqm) registered to Alfonso de Castellvi (represented by judicial administratrix Carmen M. Vda. de Castellvi) and two adjoining residential Lots 1-B (450,273 sqm) and 3 (88,772 sqm) registered to Maria Nieves Toledo-Gozun. The Republic deposited a provisional valuation of ₱259,669.10 and gained possession on August 10, 1959. Defendants moved to dismiss or to award ₱15.00 per sqm plus damages. Nine heirs of Castellvi and the husband of Toledo-Gozun intervened, all contending for ₱15.00 per sqm. Three commissioners unanimously reported a fair market value of ₱10.00 per sqm, with interest and no consequential damages. On May 26, 1961 the trialCase Digest (G.R. No. 242731)
Facts:
- Parties and Subject Lands
- Plaintiff-Appellant: Republic of the Philippines (the “Republic”)
- Filed complaint for eminent domain on June 26, 1959
- Sought expropriation over three parcels in San Jose, Floridablanca, Pampanga
- Defendants-Appellees:
- Carmen M. vda. de Castellvi (judicial administratrix of estate of Alfonso de Castellvi) – Lot 199-B, Plan SWO-23666, 759,299 m²
- Maria Nieves Toledo-Gozun – Portion Lot 1-B, Blk. 1, PSD-26254, 450,273 m² & Portion Lot 3, Blk. 1, PSD-26254, 88,772 m²
- Expropriation Proceedings and Provisional Deposits
- Republic alleged fair market value P2,000/ha (₱259,669.10 total) and deposited that amount on June 29, 1959; Court issued writ of possession August 10, 1959
- Defendants moved to dismiss or claimed P15/m²:
- Castellvi claimed P11,389,485 plus 6% interest from July 1, 1956 and ₱5,000,000 damages
- Toledo-Gozun claimed P8,085,675 plus 6% interest from October 13, 1959 and ₱50,000 attorney’s fees
- Intervenors (Castellvi heirs, Joaquin V. Gozun Jr.) also alleged P15/m²
- Commissioners’ Appointment and Report
- Three commissioners named: court’s clerk, counsel for PNB (plaintiff), counsel for defendants
- March 15, 1961 report: lands are residential; recommended ₱10/m² for all lands; ₱5,000 improvement allowance to Toledo-Gozun; 6% interest from August 10, 1959; no consequential damages
- Trial Court Decision (May 26, 1961)
- Adopted ₱10/m² as fair and just compensation
- Ordered Republic to pay 6% interest to Toledo-Gozun from August 10, 1959
- Ordered Republic to pay 6% interest to Castellvi from July 1, 1956 through July 10, 1959, then 6% on balance from July 11, 1959
- Dismissed interventions for lack of evidence; charged costs to plaintiff
- Motions, Appeals and Lower Court Orders
- Republic’s motion for new trial/reconsideration (grounds: newly discovered evidence, lack of evidence, error of law) denied July 12, 1961
- Notices of appeal by Republic and Castellvi; record on appeal delayed; appeals dismissed by CFI Pampanga for lateness; order reinstated on higher Court’s order to compile record; appellees’ motions to dismiss appeal denied by Supreme Court
- Subsequent motions (Castellvi to increase provisional value; appellees to mortgage lands) denied
- Supreme Court Proceedings and Contentions
- Republic’s errors assigned:
- Compensation of ₱10/m² excessive and unconscionable
- Taking deemed to commence in 1947 (lease inception) not 1959
- Interest starting July 1956 erroneous
- Denial of new trial based on newly discovered evidence improper
- Appellees’ position: taking commenced with filing; lands are residential valued at ₱15/m²; interest and new trial orders proper
Issues:
- When did the “taking” of the lands occur for determination of just compensation?
- What is the fair market value per square meter of the expropriated residential lands?
- From what date should interest on just compensation accrue?
- Should the Republic’s motion for new trial based on newly discovered evidence have been granted?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)