Title
Secretary of the Department of Public Works and Highways vs. Spouses Tecson
Case
G.R. No. 179334
Decision Date
Apr 21, 2015
The Supreme Court ruled that just compensation for a property taken by the Department of Public Works and Highways in 1940 should be based on the property's market value at the time of taking, and awarded an interest of six percent per annum from 1940 until full payment to compensate the owners for their loss.
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Case Digest (G.R. No. 179334)

Facts:

  • The respondents, Spouses Heracleo and Ramona Tecson, owned a 7,268-square meter property in San Pablo, Malolos, Bulacan.
  • The property was covered by Transfer Certificate of Title No. T-43006.
  • In 1940, the Department of Public Works and Highways (DPWH) took the property without initiating expropriation proceedings for the construction of the MacArthur Highway.
  • The Tecson spouses demanded payment for the property in a letter dated December 15, 1994.
  • Celestino R. Contreras, then District Engineer of the First Bulacan Engineering District of the DPWH, offered to pay P0.70 per square meter based on a 1950 Provincial Appraisal Committee (PAC) resolution.
  • Unsatisfied, the Tecson spouses demanded either the return of their property or payment at the current fair market value, leading to a complaint for recovery of possession with damages.
  • The Regional Trial Court (RTC) and the Court of Appeals (CA) ruled in favor of the Tecson spouses, valuing the property at P1,500.00 per square meter with 6% interest per annum.
  • The DPWH elevated the matter to the Supreme Court, which ruled that just compensation should be based on the 1940 value of P0.70 per square meter, with 6% interest per annum from 1940 until full payment.
  • The Tecson spouses filed a Motion for Reconsideration, arguing for a more equitable compensation.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court ruled that the just compensation should be based on the property's market value at the time of taking in 1940, which is P0.70 per square meter.
  2. The Court awarded an interest of 6% per annum from 1940 until full payment to compensate for...(Unlock)

Ratio:

  • The Supreme Court maintained that the valuation of just compensation should be based on the property's market value at the time of taking, as established in previous jurisprudence.
  • The Court emphasized that the purpose of just compensation is to compensate the owner for the loss of the property, not to reward them.
  • The true measure of compensation is the market value at the time of taking, as the owner's loss occurred at that point.
  • ...continue reading

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