Case Summary (G.R. No. 263014)
Petitioner and Respondent
G.R. No. 218628 – Petitioner: Evergreen Manufacturing Corporation; Respondent: Republic of the Philippines (DPWH)
G.R. No. 218631 – Petitioner: Republic of the Philippines (DPWH); Respondent: Evergreen Manufacturing Corporation
Key Dates
• 22 March 2004 – DPWH filed expropriation complaint and made initial deposit.
• 6 December 2004 – RTC issued writ of possession.
• 21 April 2006 – Parties agreed to DPWH’s possession.
• 15 October 2007 – Court appointed three commissioners.
• 30 June 2011 – RTC Decision fixing just compensation.
• 3 November 2011 – RTC Order denying reconsideration.
• 26 June 2014 – Court of Appeals (CA) Decision modifying compensation.
• 25 May 2015 – CA Resolution denying reconsideration.
• July–August 2015 – Both parties filed Rule 45 petitions with the Supreme Court.
Applicable Law
• 1987 Constitution, Article III, Section 9 (taking of private property and just compensation).
• Republic Act No. 8974 (procedure and initial deposit requirements for infrastructure expropriations).
• Rules of Court: Rule 45 (certiorari), Rule 67 (compensation appraisal).
Facts
• Subject property: Transfer Certificate of Title No. PT-114857, 1,428.68 sqm.
• Expropriated portion: 173.08 sqm.
• Initial deposit: ₱1,038,480 (100% of BIR zonal valuation at ₱6,000/sqm).
• Evergreen declined negotiated sale; DPWH deposited zonal value and secured possession writ.
• Three commissioners submitted separate valuations: ₱15,000/sqm; ₱30,000/sqm; ₱37,500/sqm.
RTC Ruling
The RTC fixed just compensation at ₱25,000/sqm, totaling ₱4,327,000 less the deposit withdrawn by Evergreen, resulting in ₱3,288,520 net. It denied other reliefs, including consequential damages and interest. Both parties’ motions for reconsideration were denied.
CA Ruling
The CA increased compensation to ₱35,000/sqm, totaling ₱6,057,800 minus the ₱1,038,480 deposit. It affirmed the classification as commercial, relied on two commissioners’ 2008 ocular-based reports, and denied claims for consequential damages and interest.
Issues Presented
- Evergreen’s claim for legal interest on the unpaid portion of compensation.
- DPWH’s challenge to the CA’s valuation: allegations of hearsay, reliance on non-contemporaneous data, improper use of commercial prices for an industrial classification, and uncritical application of LRTA precedents.
Supreme Court Ruling on Amount of Just Compensation
• Standard: Fair and full equivalent of owner’s loss as of the date of taking.
• Rule 45 limits review to legal errors, yet factual determinations may be revisited under established exceptions.
• Commissioners and lower courts relied on 2000 zonal valuations and 2008 market observations, without evidence pinpointing the 2004 value.
• Zonal value alone is inadequate; classification as commercial was upheld.
• To approximate the 2004 value, the Court averaged the 2000 Supreme Court-affirmed rate (₱26,100/sqm) and the lower 2008 market bound (₱35,000/sqm), yielding ₱33,050/sqm.
• Total just compensation: ₱33,050 × 173.08 sqm = ₱5,720,294.
Supreme Court Ruling on Interest
• Constitution and jurisprudence require prompt and complete compensation, including interest on unpaid balances as forbearance.
• Under RA 8974, the initial deposit does
Case Syllabus (G.R. No. 263014)
Procedural Posture
- These are consolidated petitions for review on certiorari under Rule 45 of the Rules of Court:
- G.R. No. 218628 filed by Evergreen Manufacturing Corporation (Evergreen)
- G.R. No. 218631 filed by the Republic of the Philippines, represented by the Department of Public Works and Highways (Republic-DPWH)
- Both petitions assail the Court of Appeals (CA) 26 June 2014 Decision and 25 May 2015 Resolution in CA-G.R. CV No. 98157
- The CA had affirmed with modification the Regional Trial Court (RTC), Branch 166, Pasig City:
- 30 June 2011 Decision in SCA No. 2641 for Expropriation
- 3 November 2011 Order denying motions for reconsideration
Factual Background
- Evergreen owns a 1,428.68 sqm parcel in Barangay Santolan, Pasig City (TCT No. PT-114857)
- Republic-DPWH sought to expropriate 173.08 sqm for Package 3, Marikina Bridge and Access Road under the Metro Manila Urban Transport Integration Project
- BIR zonal valuation in the vicinity set value at ₱6,000.00/sqm
- Republic-DPWH offered negotiated sale; Evergreen declined
- Republic-DPWH filed expropriation complaint on 22 March 2004 and deposited ₱1,038,480.00 (100% of zonal value)
- RTC issued Writ of Possession on 6 December 2004; parties agreed on entry on 21 April 2006
- Evergreen moved to withdraw the deposit; RTC granted on 15 November 2006
- Pre-trial narrowed dispute to amount of just compensation
- Three commissioners appointed on 15 October 2007; submitted divergent appraisal reports:
- BIR representative: ₱15,000.00/sqm
- Atty. Jade Ferrer Wy: ₱37,500.00/sqm
- Atty. Pablita Migrino: ₱30,000.00/sqm
RTC Ruling
- 30 June 2011 Decision fixed just compensation at ₱25,000.00/sqm
- Directed payment of net ₱3,288,520.00 (after deducting initial deposit) plus unpaid taxes and fees
- Denied other reliefs of Evergreen for lack of merit; adjudged costs against Republic-DPWH
- 3 November 2011 Order denied both parties’ motions for partial reconsideration
CA Decision and Resolution
- 26 June 2014 Decision increased just compensation to ₱35,000.00/sqm (total ₱6,057,800.00), minus ₱1,038,480