G.R. No. 216723 - Republic vs. Villao

On March 18, 2004, the petitioner, Republic of the Philippines represented by the Department of Public Works and Highways (DPWH), filed a Complaint for the expropriation of a 550-square meter parcel of land located at Barrio Binakayan, Kawit, Cavite.
The subject property was covered by Transfer Certificate of Title No. T-35696 and was registered in the name of Pacita Villao.
The expropriation was linked to the Manila-Cavite Tollways Expressway Project (MCTEP), specifically the R-1 Extension Expressway, Segment 4.

Petitioner later sought and was granted leave to file an Amended Complaint, which impleaded Carmienett Javier as defendant, owner of improvements constructed on the subject property.
Subsequent service of summons was effected upon Javier following the amendment.

Petitioner deposited with Land Bank of the Philippines (LBP), South Harbor Branch, the following amounts as an initial payment:

₱1,045,000.00 for the land (based on a zonal valuation of ₱1,900.00 per square meter),
₱81,868.50 for a one-storey semi-concrete house, and
₱186,343.30 for a one-storey wooden house.

Later, a motion was granted by the RTC allowing respondents to withdraw these deposited amounts corresponding to their respective interests.

On November 25, 2004, the RTC of Imus, Cavite issued an Order granting the petitioner’s Motion for Issuance of a Writ of Possession on Villao’s property, and simultaneously allowed the amendment of the Complaint to include Javier.
On June 23, 2005, another RTC Order directed the release of the deposited funds to the respective respondents.
On April 1, 2008, the RTC created a Board of Commissioners (BOC) tasked with determining the proper just compensation for the property.
On August 15, 2011, the BOC delivered its Report, recommending a valuation of ₱9,000.00 per square meter as the “most reasonable and fair market value” for the subject property.

The Report considered factors such as location, neighborhood, utilities, physical characteristics, occupancy, usage, and the highest and best use of the property.
It notably relied on the RTC Decision in Tapawan (Civil Case No. 0009-04) due to factual and geographical similarities, despite the mixed commercial-residential nature of comparable properties being valued higher in other listings.

On October 24, 2011, the RTC rendered a Decision adopting the BOC’s valuation, thereby condemning the property and setting just compensation at ₱4,950,000.00 (550 sq.m. x ₱9,000.00).

Given the initial deposit of ₱1,045,000.00 by the petitioner, an additional sum of ₱3,905,000.00 was ordered to be paid, with legal interest calculated from the date of the taking of the property.

Petitioner appealed the RTC Decision before the CA.
The CA, affirming the RTC ruling, accepted that the BOC’s Report was supported by both documentary evidence and personal inspections, and that the factors considered were sufficient under the applicable law (notably R.A. No. 8974).
Petitioner’s Motion for Reconsideration was denied in the issued Resolution dated February 4, 2015.

The alleged hearsay nature of the BOC’s Report and its reliance on the Tapawan decision, and
The contention that the valuation was based on “current market offerings” rather than the fair market value as of the date of the filing of the original complaint.

Respondents maintained that the BOC’s methodology was sound, as it incorporated both documentary and firsthand evidence obtained through ocular inspections.

Whether the Commissioners’ Report, which heavily relied on the valuation from the Tapawan case, constituted inadmissible hearsay lacking sufficient documentary support.
Whether the report’s reliance on the facts observed during ocular inspections and documentary evidence lent it the requisite credibility.

Whether the just compensation should be determined based on the market value as of the filing of the expropriation complaint (March 18, 2004) rather than on “current market offerings” as evidenced later by comparable properties.
Whether the reliance on the RTC’s decision in Tapawan was appropriate where the contextual specifics, such as the timing of the valuation and factual details of the complaint, were not clearly analogous.

Whether the methodology for computing legal interest on the unpaid balance—using different rates from the date of the writ of possession and thereafter as the decision reached finality—is in accordance with precedent and proper principles governing expropriation.