Case Summary (G.R. No. 169453)
Background of Expropriation Proceedings
On August 24, 1999, PHIVIDEC initiated expropriation proceedings against Capitol Steel, filing a case before the Regional Trial Court (RTC) of Misamis Oriental, which initially led to a writ of possession being issued. However, the case was dismissed due to PHIVIDEC's unauthorized engagement of a private lawyer. Subsequently, PHIVIDEC attempted to reenter the expropriation process, aiming to secure the properties for the Mindanao International Container Terminal Project (MICTP).
Valuation and Legal Proceedings
Capitol Steel requested a revaluation of its properties from the Bureau of Internal Revenue (BIR), resulting in the issuance of a valuation of P700 per square meter by the Technical Committee on Real Property Valuation (TCRPV). In contrast, PHIVIDEC's valuation, based on Department Order No. 40-97, indicated lower prices of P300 and P500 per square meter for the lands in question. PHIVIDEC later refiled for expropriation on November 24, 2003, which again saw motions surrounding the issuance of a writ of possession.
Court Orders and Appeals
On February 3, 2004, the RTC denied PHIVIDEC’s motion for a writ of possession, citing the valuation discrepancy and the need for a full trial to determine the proper compensation. The matter was appealed, and the Court of Appeals, on February 7, 2005, ruled in PHIVIDEC's favor, mandating the issuance of the writ and stating that the lower court had erred in valuing the properties using the TCRPV figures, which were not compliant with the BIR guidelines for current valuations.
Issues of Compliance with R.A. 8974
R.A. 8974 outlines the requirements for expropriation, including the immediate payment of 100% of the property's zonal valuation to facilitate a writ of possession. The appellate court found that PHIVIDEC had met the necessary requirements under the law by proposing a valuation based on the prevailing BIR zonal value figures under D.O. 40-97 rather than the contested TCRPV valuation.
Supreme Court's Findings
The Supreme Court analyzed the procedural and substantive aspects of the case, affirming that the requirements set out in R.A. 8974 regarding immediate entry for expropriation proceedings were satisfactorily complied with by PHIVIDEC. The Court emphasized that the correct procedure involves strict adherence to the zonal eva
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Case Background
Parties Involved:
- Petitioner: Capitol Steel Corporation, a domestic corporation owning 65 parcels of land totaling 337,733 square meters in Misamis Oriental.
- Respondent: Phividec Industrial Authority (PHIVIDEC), a government-owned corporation with the power of eminent domain under Presidential Decree No. 538.
Purpose of Expropriation:
- The properties of Capitol Steel are designated as the ideal site for the Mindanao International Container Terminal Project (MICTP), which aims to enhance port capabilities in Mindanao.
Procedural History
Initial Expropriation Case:
- On August 24, 1999, PHIVIDEC filed for expropriation in the RTC of Misamis Oriental, leading to a writ of possession issued on September 1, 1999. However, the case was dismissed due to improper legal representation.
Subsequent Developments:
- Capitol Steel requested a revaluation of its properties in March 2001. The Technical Committee on Real Property Valuation (TCRPV) evaluated and set the zonal value at P700 per square meter in December 2001.
- The Supreme Court annulled the previous expropriation proceedings in October 2003, prompting PHIVIDEC to inform Capitol Steel of a new expropriation case and the deposit of P116,563,500, representing the zonal value of the properties.
Court Orders and Rulings
Writ of Possession Application:
- On December 8, 2003, PHIVIDEC filed an urgent motion for a writ of possession, attaching evidence of the funds deposited according to the provisions of Republic Act No. 8974.
RTC Decisions:
- The RTC denied PHIVIDEC's motion for a writ of possession on February 3, 2004, citing that the deposit was inadequate and that a judicial interpretation of the zonal valuation was necessary