G.R. No. 140377 - Tiongson vs. National Housing Authority

The National Housing Authority (NHA) took possession in 1978 of parcels of land belonging to petitioners under Presidential Decree No. 1669 and No. 1670.
Under PD No. 1669, the so-called Tambunting Estate—registered under several TCT numbers—was expropriated for the sale at cost to bona fide occupants and squatter families, with an additional purpose to upgrade the properties.
Similarly, PD No. 1670 provided for the expropriation of properties along the Estero de Sunog-Apog, again for sale to qualifying occupants under similar terms.

In G.R. Nos. L-55166 and 55167 (Decision dated May 21, 1987), this Court declared PD No. 1669 and PD No. 1670 unconstitutional and null and void, holding that they violated petitioners’ right to due process.
The Supreme Court’s decision in these cases became final and executory, affecting the legitimacy of the NHA’s initial possession.

On September 14, 1987, subsequent to the Supreme Court ruling, the NHA filed its Petition for Expropriation before the Regional Trial Court (RTC) of Manila, initiating expropriation proceedings on parcels of land that were partly involved in the earlier case.
On April 29, 1997, Branch 41 of the RTC ruled that the computation of just compensation should be based on the filing date of the expropriation complaint (September 14, 1987).
The RTC later denied the NHA’s motion for reconsideration on August 5, 1997, maintaining the filing date as the reckoning point for just compensation.

The NHA assailed the RTC orders through a petition for certiorari before the Court of Appeals.
The CA, by its June 16, 1999 decision, reversed the RTC’s ruling and held that just compensation was to be computed from the actual taking of the properties in 1978.
Petitioners moved for reconsideration of the CA decision, but their motion was denied by the CA on October 7, 1999.

Petitioners argued that since the taking of the properties in 1978 occurred under policies (PD No. 1669) later declared unconstitutional, the proper reckoning date for just compensation should not be the date of possession but rather the date of the expropriation complaint filing, that is, September 14, 1987.
In its expropriation petition filed before the RTC, the NHA contained judicial admissions—including an Order dated June 15, 1988—which acknowledged that possession of the subject properties commenced in 1978.
These judicial admissions, while noted, were argued to be inconsistent with the appropriate application of the legal rule regarding the proper reckoning period in light of the unconstitutional basis of the original taking.

Pursuant to Section 4 of Rule 67 of the Rules of Court, the just compensation in expropriation cases may be determined as of the date of either the taking of the property or the filing of the expropriation complaint—whichever occurred first.
The factual and judicial backdrop includes multiple admissions of possession, juxtaposed with the constitutional invalidation of the decrees that justified such possession, thereby raising questions on which date is legally determinative for compensation.

The CA’s decision favoring the 1978 possession date was later challenged through a petition for review on certiorari in this Court.
The issues revolve around the appropriate temporal basis for the computation of just compensation in light of the ensuing constitutional issues.

Whether the just compensation for the expropriated properties should be reckoned from the actual taking of the property in 1978 or from the filing of the expropriation complaint on September 14, 1987.
Whether the judicial admissions in NHA’s expropriation petition and the framework provided in Rule 67, Section 4 of the Rules of Court mandate the compensation be determined from the filing date, especially considering the unconstitutionality of PD No. 1669 and No. 1670.