Case Digest (G.R. No. 179334) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1940, the Department of Public Works and Highways (DPWH) entered and permanently occupied the 7,268‐square‐meter parcel of Spouses Heracleo and Ramona Tecson in San Pablo, Malolos, Bulacan (TCT No. T-43006) for the construction of the MacArthur Highway without initiating expropriation proceedings or paying compensation. On December 15, 1994 the Tecsons demanded payment; DPWH offered P0.70 per square meter based on the Provincial Appraisal Committee’s 1950 resolution. Unsatisfied, the Tecsons filed a complaint for recovery of possession with damages on March 17, 1995 before RTC Branch 80, Malolos City, claiming a valuation of P2,543,800.00. The RTC (2002) awarded P1,500.00 per square meter plus 6% annual interest from filing; the CA (2007) affirmed with 6% interest from March 17, 1995 until full payment. In a July 1, 2013 Third Division decision, the Supreme Court granted the petition in part, resetting just compensation to P0.70 per square meter with 6% interest from the date Case Digest (G.R. No. 179334) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Taking of property
- In 1940, the Department of Public Works and Highways (DPWH) took respondents-movants’ 7,268-sqm property in Malolos, Bulacan for construction of MacArthur Highway without expropriation proceedings or payment of compensation.
- No expropriation case was filed and DPWH immediately entered into possession.
- Demand and suit
- By letter dated December 15, 1994, respondents demanded just compensation; DPWH offered ₱0.70 per sqm based on the Bulacan Provincial Appraisal Committee resolution.
- Unsatisfied, respondents filed a complaint for recovery of possession with damages on March 17, 1995 (1995 Complaint).
- Judicial proceedings
- RTC, Branch 80, Malolos (2002): valued property at ₱1,500/sqm with 6% interest from filing.
- CA, Second Division (2007): affirmed RTC award, 6% interest from March 17, 1995 until payment.
- SC Third Division (July 1, 2013): granted government‐petition in part, reduced valuation to ₱0.70/sqm (1940 value), 6% interest from date of taking.
Issues:
- Basis of valuation
- Should just compensation be based on the property’s market value at the time of actual taking (1940) or at the time of filing of the complaint (1995)?
- Can present‐day market value (e.g. ₱1,500/sqm) apply when taking occurred decades earlier?
- Incidental reliefs
- What is the correct interest rate and reckoning date for delay in payment?
- Are respondents entitled to exemplary damages and attorney’s fees for DPWH’s illegal taking without expropriation proceedings?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)