Facts:

• Spouses Herbert E. Buot and Ophelia R. Completo (Spouses Buot) own agricultural land in Abugon, Sibonga, Cebu, covered by Transfer Certificate of Title No. P-2260.
• The National Transmission Corporation (TransCo), later substituted by the National Grid Corporation of the Philippines (NGCP), filed an expropriation complaint with the Regional Trial Court (RTC) of Argao, Cebu.
• TransCo aimed to acquire a 196-square-meter portion of the property and enforce an easement of right-of-way over 7,382 square meters for its Naga-Suba 138KV T/L Upgrading Project.
• Spouses Buot opposed, arguing the project would render their property useless and sought just compensation for the entire lot.
• The RTC appointed a Panel of Commissioners to determine the fair market value and issued a writ of possession in favor of TransCo after it paid a provisional amount.
• The RTC ruled NGCP should pay P1,000.00 per square meter for the expropriated portion, totaling P7,578,000.00, plus P567,500.00 for improvements.
• The Court of Appeals (CA) set aside the RTC's decision, remanding the case for further determination of just compensation and execution of a quitclaim for the legal easement of right-of-way.
• Both Spouses Buot and NGCP sought reconsideration, which the CA denied, leading to a petition before the Supreme Court.

Issue:

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Ruling:

• The Supreme Court partly granted the petition.
• It affirmed the CA's decision with modification, remanding the case to the RTC for further proceedings to determine consequential damages and the value of improvements on the property affected by the legal easement of right-of...(Unlock)

Ratio:

• The Supreme Court held that power and transmission lines are "similar works" under Section 112 of Commonwealth Act No. 141, allowing the government to enforce a legal easement of right-of-way not exceeding 60 meters in width on lands granted by patent.
• The Court applied the principle of ejusdem generis, interpreting general words following specific items as applying only to items of the same kind.
• The installation of transmission lines falls within the general clause of "similar works" intended for public use.
• The subject property, originally public land granted by free patent, is subject to the Public Land Act, including the legal easement of right-of-way.
• NGCP is not liable to pay just compensation for the 7,382-square-meter portion within the 60-meter wide easement, except for the val...continue reading