G.R. No. 266921 - National Transmission Corporation vs. Spouses Louis Marco Manalo and Rowena Marie Manalo, represented by Freddie M. Arguelles, et al.

Respondents – spouses Louis Marco S. Manalo, Rowena Marie T. Manalo, Nonylon D. Pedraja, and Nonna D. Pedraja, represented respectively by Freddie M. Arguelles and Julianito B. Moncayo – filed a complaint for inverse condemnation under Rule 67 of the Rules of Court.
Petitioner – National Transmission Corporation (TRANSCO), a government corporation conferred with eminent domain power to acquire transmission assets from the National Power Corporation (NAPOCOR) – is the defendant in the proceedings.

In 1998, NAPOCOR (predecessor of TRANSCO) constructed a 500-kilovolt (KV) transmission line traversing the subject lots to transmit electric power from Batangas to Laguna and Metro Manila.

The respondents initiated the inverse condemnation proceedings by filing the Complaint, seeking determination and fixation of the fair market value of their properties pursuant to Republic Act No. 10752.
On September 15, 2020, respondents filed a Motion to Require Defendant to Comply with Republic Act No. 10752, arguing that the procedural and substantive aspects of compensation should be governed by the said law.
TRANSCO filed its Answer, asserting that the expropriation taking was conducted without initiating expropriation proceedings and arguing that the computation of provisional deposit should be based on Rule 67’s assessed value rather than the zonal valuation mandated under Republic Act No. 10752.

The Regional Trial Court (RTC) issued an Order on January 14, 2021, granting the Motion, and required TRANSCO to deposit an amount initially computed at PHP 47,818,500.00, later adjusted to PHP 70,288,500.00, as provisional compensation based on the 100% current zonal value pursuant to Republic Act No. 10752.
The Court of Appeals (CA) affirmed the RTC’s decision in a December 12, 2022 Decision and reiterated the applicability of Republic Act No. 10752 over Rule 67, a position later reaffirmed in the Resolution dated April 4, 2023.
Dissatisfied with the rulings, TRANSCO raised a Petition for Review on Certiorari, contending that the computation for provisional deposit should be based on Rule 67 and arguing against the retroactive application of Republic Act No. 10752.

The central factual issue surrounds the proper legal basis for computing the provisional compensation: whether to follow the statutory mandate provided by Republic Act No. 10752 or the procedural rule of Rule 67 of the Rules of Court.
TRANSCO’s contention centers on its view that the transmission line’s construction long before the enactment of Republic Act No. 10752 should invoke the rules in effect at the time, while respondents maintain that the filing of the inverse condemnation complaint after the law’s effectivity necessitates its application.

Whether Republic Act No. 10752 is the applicable law in determining the provisional compensation for the subject lots, as opposed to the provisions of Rule 67 of the Rules of Court.
Whether the computation of provisional deposit should be based on the current Bureau of Internal Revenue’s (BIR) zonal valuation as mandated by Republic Act No. 10752, instead of the assessed value under Rule 67.
Whether the retroactive application of Republic Act No. 10752 to a transmission line constructed in 1998 is justified given that the inverse condemnation proceedings were initiated after the law’s enactment.