Case Digest (G.R. No. 179334)
Facts:
Secretary of the Department of Public Works and Highways and District Engineer Celestino R. Contreras v. Spouses Heracleo and Ramona Tecson, G.R. No. 179334, April 21, 2015, the Supreme Court En Banc, Peralta, J., writing for the Court.Petitioners are the Secretary of the Department of Public Works and Highways (DPWH) and District Engineer Celestino R. Contreras; respondents are spouses Heracleo and Ramona Tecson (landowners). In 1940 the DPWH took respondents’ 7,268‑sq.m. parcel for the construction of MacArthur Highway without instituting expropriation proceedings or paying just compensation.
After decades of inaction by the government, respondents demanded payment on December 15, 1994. The DPWH (through Contreras) offered P0.70 per square meter based on a Provincial Appraisal Committee (PAC) resolution. Unsatisfied, respondents filed a complaint for recovery of possession with damages on March 17, 1995 in the Regional Trial Court (RTC), Malolos (Civil Case No. 208‑M‑95). The RTC awarded P1,500.00 per square meter; the Court of Appeals (CA) affirmed with modification and added 6% interest from filing (March 17, 1995) until full payment.
Petitioners sought review in the Supreme Court by a petition for review on certiorari (Rule 45). In the Third Division’s July 1, 2013 Decision the Court partially granted the petition by modifying the CA’s valuation to P0.70 per square meter — the property’s fair market value at the time of taking in 1940 — and ordered interest at 6% per annum from the date of taking (1940) until full payment.
Respondents moved for reconsideration, arguing the award based on 1940 value was arbitrary and "confiscatory" and urging a “happy middle ground” (including proposals to compute present value or compounded returns). Because members of the Third Division could not agree on the motion, the matter was referred to the En Banc.
The En Banc considered (a) whether to revisit the July 1, 2013 ruling and (b) the proper computation of just compensation, interest and damages. The Court reaffirmed that just compensation is measured by fair market value at the time of taking and that interest is awarded to compensate for the State’s forbearance; it applied historical interest‑rate authorities (Act No. 2655; Central Bank/BSP circulars) and Article 2212 of the Civil Code to compute interest, awarded exemplary damages and attorney’s fees, and denied respondents’ motion for reconsideration. The Court calculated — for illustrative purposes as of Sept...(Pro-only)
Issues:
- Should the Motion for Reconsideration of the Court’s July 1, 2013 Decision be granted?
- Is just compensation for the DPWH’s 1940 taking properly measured by the property’s fair market value at the time of taking, and if so, what is the proper valuation date?
- What interest rate(s), method of computation (simple vs. compound) and accrual dates should apply to the unpaid just compensation?
- Are exemplary damages and attorney’s fees warranted because the government took the property without expropr...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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