Case Digest (G.R. No. 131516) Core Legal Reasoning Model
Facts:
This case revolves around G.R. No. 246565, where petitioners Ricardo S. Schulze, Sr., represented posthumously by his wife Ana Maria L. Schulze as President of Elaris Investment Co., Inc., along with Jose Luis S. Valdes, the spouses Maria Elena and Antonio Valdes, and Elaris Investment Co., Inc., filed a petition against respondents National Power Corporation (NAPOCOR) and the Philippine National Bank (PNB). The dispute originated on September 7, 2001, when NAPOCOR filed a complaint for expropriation before the Regional Trial Court (RTC) in Bacolod City, relating to certain lots in Barangay Granada, Bacolod City, Negros Occidental, which were required for the construction and maintenance of the Bacolod-Cadiz Transmission Line for the Negros IV-Panay Project. The total area expropriated was 23,563 square meters, which constituted part of larger tracts of land totaling 470,443 square meters.
In their response to the expropriation complaint, petitioners argued that the value of th
Case Digest (G.R. No. 131516) Expanded Legal Reasoning Model
Facts:
- Parties and Initiation of the Case
- Petitioners:
- Ricardo S. Schulze, Sr. (substituted by his wife, Ana Maria L. Schulze, as President of Elaris Investment Co., Inc.),
- Jose Luis S. Valdes,
- Spouses Antonio and Maria Elena S. Valdes, and
- Elaris Investment Co., Inc.
- Respondents:
- National Power Corporation (NAPOCOR) and
- Philippine National Bank (PNB).
- Expropriation Complaint and Subject Property
- On September 7, 2001, NAPOCOR filed a complaint for expropriation before the Regional Trial Court (RTC) seeking an easement (right-of-way) over certain portions of property in Barangay Granada, Bacolod City, Negros Occidental, for the construction and maintenance of the 138 KV Bacolod-Cadiz Transmission Line (Negros IV-Panay Project).
- The subject lots have an aggregate area of 23,563 square meters (sq. m.) and were part of five larger tracts totaling 470,443 sq. m.
- Petitioners argued that:
- The assessed and market values of their lands had increased significantly over time;
- The remainder of their lots (affected lots) would suffer a reduction in value due to the installation of NAPOCOR’s posts, transmission lines, transformers, and other facilities, thus warranting consequential damages.
- Determination of Just Compensation at the RTC
- The RTC, guided by a Board of Commissioners’ valuation, adopted a valuation rate of P593.86 per sq. m. for the subject lots based on market data from 2002 and 2003 and other pertinent factors such as location and utility.
- In its Decision dated January 18, 2010, the RTC fixed the just compensation at P13,993,260.00 and awarded:
- Consequential damages amounting to P26,538,415.68 (computed as 10% of the fair market value of the affected lots), and
- Attorney’s fees of P100,000.00.
- Court of Appeals (CA) Ruling
- The CA, in a Decision dated September 18, 2017, upheld the RTC’s determination of just compensation based on uncontroverted, ocularly-inspected facts.
- The CA found the award of consequential damages speculative and remanded the case to the RTC for further evidence to determine such damages properly.
- The CA also deleted the award for attorney’s fees, citing the absence of any irregularity in the expropriation proceedings, and denied petitioners’ claim for legal interest due to their failure to appeal on that issue.
- Subsequent Developments and the Supreme Court’s Intervention
- Petitioners filed for review on certiorari, challenging:
- The CA’s remand for determining consequential damages, and
- The failure to impose legal interest on the just compensation award.
- A motion for partial reconsideration of the CA’s decision was filed by petitioners but was denied in a Resolution dated February 26, 2019, prompting the present petition before the Supreme Court.
Issues:
- Whether the Court of Appeals erred in remanding the case to determine the proper amount of consequential damages for the affected (non-expropriated) portions of the property.
- Was the factual and evidentiary basis for the award of consequential damages sufficiently established?
- Was the use of 10% of the fair market valuation appropriate, or should the established formula (50% of the Bureau of Internal Revenue (BIR) zonal valuation) be applied?
- Whether the CA erred in failing to impose legal interest on the award of just compensation.
- Does the failure to appeal the RTC’s silence on legal interest justify the omission of interest in the final awards?
- Should legal interest be imposed to compensate for the delay in full payment of just compensation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)