Case Digest (G.R. No. 253069)
Facts:
Republic of the Philippines, represented by the Toll Regulatory Board (TRB) v. Spouses Roberto and Rosemarie Roxas and Export and Industry Bank, G.R. No. 253069, June 26, 2023, Supreme Court Second Division, Kho, Jr., J., writing for the Court.The Republic, through the TRB, filed a Complaint for expropriation on August 3, 2005 to implement the South Luzon Tollway Extension (SLTE) Project pursuant to Presidential Decree No. 1112. The subject was a 79‑sqm parcel in Barangay San Rafael, Sto. Tomas, Batangas (TCT No. T‑49561), with zonal value PHP 475.00/sqm; the title bore an annotation of mortgage in favor of Export and Industry Bank. Respondents Spouses Roberto and Rosemarie Roxas did not contest the government’s right to expropriate but disputed the mortgage annotation and claimed the land’s market value at PHP 3,500.00/sqm and the improvements at PHP 1,500,000.00.
The Regional Trial Court (RTC), Branch 6, Tanauan, Batangas, issued an Order of Expropriation and appointed three commissioners (Register of Deeds Atty. Abraham N. Vermudez, Municipal Assessor Ester Francisco, and Municipal Engineer Nolando B. Sanchez) to ascertain just compensation. Petitioner deposited PHP 501,125.18 representing what it considered 100% of zonal value and value of the house; a Writ of Possession was issued on September 24, 2007.
The commissioners recommended PHP 3,500.00/sqm for the land and PHP 806,000.00 for reproduction cost of the improvements, citing a barangay chief’s certificate, a 2003 sale, and independent appraisals. Petitioner contested those bases and produced testimony (Engr. Allan Plete) estimating PHP 1,300–1,500.00/sqm for the area. In a Decision dated December 7, 2015, the RTC rejected the commissioners’ lot valuation for lack of corroborating evidence other than the barangay certificate, fixed just compensation for the land at PHP 2,700.00/sqm (PHP 213,300.00) and for improvements at PHP 806,000.00 (total PHP 1,019,300.00), ordered payment of the balance (less the deposit) plus legal interest from filing, and awarded commissioners’ fees. Petitioner’s motion for reconsideration was denied on September 28, 2016.
Petitioner appealed to the Court of Appeals (CA). In a Decision dated May 23, 2019, the CA affirmed the RTC’s valuation but deleted the award of commissioners’ fees, citing Rule 141, Section 22 of the Rules of Court (exemption of the Republic from ...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in affirming the amount of just compensation fixed by the RTC (PHP 2,700.00/sqm for the land and PHP 806,000.00 for improvements) for the expropriated property?
- Did the Court of Appeals err in imposing legal interest on the difference between the initial deposit and the final adjudged just compensation, and if not, at what rates and p...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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