Case Summary (G.R. No. 160890)
Relevant Dates
- April 15, 1996: NAPOCOR filed the Complaint for Eminent Domain.
- August 1, 1996: NAPOCOR deposited the assessed value of the property as required.
- August 15, 1996: BPI was notified of NAPOCOR's intent to take possession of the property.
- February 26, 1999: Commissioners submitted their report assessing just compensation.
- August 5, 1999: The Regional Trial Court rendered judgment in favor of BPI.
- August 30, 2002: The Court of Appeals reversed the lower court's decision.
- November 10, 2004: The Supreme Court issued its decision.
Procedural Background
Initially, NAPOCOR sought to expropriate a portion of BPI's land by filing a complaint. Following the statutory procedure, it deposited an assessed value of P3,013.60 with the Philippine National Bank and subsequently moved to take possession of the property, which the trial court granted. BPI, citing procedural issues, sought to dismiss the case, leading to a series of motions and reconsiderations, ultimately resulting in the appointment of commissioners to determine just compensation.
Commissioner's Valuation
On February 26, 1999, three commissioners submitted a report estimating the compensation for the 75.34 square meter property at P1,278,060.00, using a Market Data Approach. This valuation was based on comparisons with sales of similar properties in the vicinity. The trial court accepted this valuation and ordered NAPOCOR to compensate BPI accordingly, with additional fees for the commissioners.
Court of Appeals Decision
The Court of Appeals reviewed the decision and concluded that BPI was entitled to P3,000.00 per square meter instead of the originally assessed P10,000.00. It reversed the trial court's ruling and reduced both the compensation and the commissioners' fees. BPI's motion for reconsideration of this decision was denied.
Legal Standard for Just Compensation
In expropriation cases, just compensation is defined as the fair market value of the property at the time of taking. It is based on what an informed buyer and seller would agree upon in an open market, uncompelled to transact. The Supreme Court underscored that compensation should not benefit the taker but should ensure equitable remuneration to the owner.
Supreme Court Analysis
Upon reviewing the case, the Supreme Court highlighted the appellate court's findings were substantiated and based on the credible report that just compensation should align with the fair and reasonable market values established by the Provincial Appraisal Committee of Cavite, which had set the local property value at P3,000.00 per squ
...continue readingCase Syllabus (G.R. No. 160890)
Case Overview
- The case pertains to a petition for review under Rule 45 of the Rules of Court.
- Petitioner: Bank of the Philippine Islands (BPI).
- Respondents: Court of Appeals and National Power Corporation (NAPOCOR).
- Focus: The appeal challenges the Court of Appeals' decision which reversed a lower court's ruling regarding just compensation for expropriated land.
- Decision Date: November 10, 2004.
Background of the Case
- On April 15, 1996, NAPOCOR filed a Complaint for Eminent Domain to expropriate a portion of BPI's property in Barrio Bucal, Dasmariñas, Cavite, for a transmission line project.
- NAPOCOR deposited P3,013.60 with the Philippine National Bank, as per the assessed value of the property, on August 1, 1996.
- Notification of intent to take possession was sent to BPI on August 15, 1996.
- BPI's motions for bill of particulars were denied, and a subsequent motion to dismiss was granted without prejudice.
Proceedings in the Trial Court
- NAPOCOR's motion for reconsideration led to the reinstatement of the case.
- On November 28, 1997, the trial court appointed three commissioners to assess just compensation.
- The commissioners submitted a report on February 26, 1999, valuing the property at P10,000.00 per square meter, totaling P753