G.R. No. 240720 - Spouses Buot vs. National Transmission Corp.

Spouses Herbert E. Buot and Ophelia R. Completo (Spouses Buot) are the registered owners of Lot No. 1415 CAD 315-D, located in Abugon, Sibonga, Cebu, covered by Transfer Certificate of Title No. P-2260 and classified as agricultural land with an area of approximately 117,850 square meters.
The land was originally registered pursuant to a free patent with a general reservation for all conditions, public easements, and servitudes as prescribed by law.

National Transmission Corporation (Transco) and National Grid Corporation of the Philippines (NGCP)

Transco filed a complaint for expropriation before the Regional Trial Court (RTC) against Spouses Buot, seeking acquisition of a 196-square-meter portion of the subject property and enforcement of a legal easement of right-of-way over 7,382 square meters for the Naga-Suba 138KV Transmission Line (T/L) Upgrading Project.
NGCP subsequently took over Transco's operations and was substituted as plaintiff.

The Spouses opposed the expropriation, claiming that the danger and hazards posed by the transmission towers would render the entire property useless.
They sought just compensation not only for the 7,578 square meters affected by the transmission lines (existing plus proposed) but effectively for the entire property because of the adverse impact.

The RTC appointed a Panel of Commissioners to determine the fair market value of the property.
A writ of possession was issued in favor of Transco/NGCP after provisional payment of P5,114,300.00 to Spouses Buot.
The RTC ruled that just compensation should be P1,000 per square meter for the expropriated 7,578 square meters plus payment for improvements, amounting to a total of P8,145,500.00.
The Court of Appeals (CA) set aside the RTC Decision and remanded the case for:

Proper determination of the just compensation considering the 60-meter wide reservation under the legal easement of right-of-way pursuant to Section 112 of Commonwealth Act (CA) No. 141;
Execution of a quitclaim over the property covered by the legal easement; and
Reevaluation of the value of improvements including the valuation of trees actually growing on the property.

The CA held that power and transmission lines fall under similar works covered by Section 112 of CA No. 141 allowing appropriation without compensation for land within a 60-meter wide right-of-way, save damages to improvements.
Spouses Buot moved for reconsideration, seeking compensation for the entire property, while NGCP sought modification of the CA Decision. Both motions were denied by the CA.

Spouses Buot filed a Petition for Review on Certiorari seeking reversal of the CA Decision.
Issues raised include the interpretation of Section 112 of CA No. 141 and the proper determination of just compensation.

Whether power and transmission lines are included under the "similar works" subject to a legal easement of right-of-way under Section 112 of Commonwealth Act No. 141.
Whether the Court of Appeals erred in remanding the case to the RTC for the determination of just compensation for:

The actual area of expropriation after deducting the legal easement of right-of-way;
The value of the affected improvements; and
The consequential damages for the "dangling" or unusable areas beyond the 60-meter easement.

Whether the RTC’s valuation of just compensation at P1,000.00 per square meter for the expropriated portion of the property is supported by substantial evidence and complies with Section 5 of Republic Act No. 8974.