Case Digest (G.R. No. 170740)
Facts:
- Julita P. Tan is the petitioner; the Republic of the Philippines, represented by the Public Estates Authority (PEA), is the respondent.
- Tan became the registered owner of a 7,161 square meter parcel of land in Las Piñas City, evidenced by Transfer Certificate of Title (TCT) No. 78188.
- She acquired the property from San Antonio Development Corporation (SADC) through an "Irrevocable and Exclusive Special Power of Attorney" dated April 6, 2001, assuming SADC's tax obligations.
- On March 29, 1985, PEA requested SADC's permission to enter the property for the construction of the southern abutment of the Zapote Bridge, which SADC granted for a monthly rental of P10,000.
- Negotiations for the sale of the property between PEA and SADC lasted twenty years without agreement.
- In October 2000, SADC demanded compensation based on current zonal value and interest for property use since 1985.
- Tan acquired the property in April 2001, and the Bureau of Internal Revenue (BIR) assessed its zonal value at P20,000 per square meter.
- PEA collected toll fees from the Coastal Road but refused to compensate Tan.
- A proposed land swap in 2002 was withdrawn by PEA in 2003, leading to PEA filing for expropriation in the Regional Trial Court (RTC), claiming just compensation based on the 1985 zonal value of P2,900 per square meter.
- Tan argued for compensation based on the current zonal value of P20,000 per square meter.
- The RTC ordered PEA to pay Tan P94,380,000 based on BIR's valuation, but this was reversed by the Court of Appeals.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of Julita P. Tan, reversing the Court of Appeals' decision.
- The Court held that the RTC's orders were final and appealable.
- Just compensation should be b...(Unlock)
Ratio:
- The Supreme Court emphasized that the RTC's orders were final, determining just compensation for the property.
- PEA's use of certiorari was inappropriate as it served as a substitute for a lost appeal.
- Under Section 9, Article III of the 1987 Constitution, private pr...continue reading
Case Digest (G.R. No. 170740)
Facts:
The case involves Julita P. Tan as the petitioner and the Republic of the Philippines, represented by the Public Estates Authority (PEA), as the respondent. The events leading to the case began when Julita P. Tan became the registered owner of a 7,161 square meter parcel of land located at the southern bank of the Zapote River in Sitio Wawa, Pulang Lupa, Las Piñas City, as evidenced by Transfer Certificate of Title (TCT) No. 78188. She acquired this property from the San Antonio Development Corporation (SADC) through an "Irrevocable and Exclusive Special Power of Attorney" dated April 6, 2001, which included her assumption of SADC's obligation to pay all taxes on the land. Prior to this transfer, on March 29, 1985, PEA had requested SADC for permission to enter the property to construct the southern abutment of the Zapote Bridge as part of the Manila-Cavite Coastal Road project. SADC granted this request under the condition that PEA would pay a monthly rental of P10,000.
Negotiations ensued between PEA and SADC regarding the sale of the property, but no agreement was reached over the next twenty years. In October 2000, SADC demanded compensation based on the current zonal value and interest for the use of the property since 1985. In April 2001, Tan acquired the property from SADC. The Bureau of Internal Revenue (BIR) later assessed the zonal value of the property at P20,000 per square meter. Despite PEA's collection of substantial toll fee...