Case Summary (G.R. No. 232119)
Factual Background
On April 15, 2010, NGCP filed a Complaint for Eminent Domain seeking to acquire upon payment of just compensation portions of two agricultural lots owned by the respondents for the construction and maintenance of the Abaga-Kirahon 230 kV Transmission Line Project. The combined area affected totaled 7,973.03 square meters and NGCP deposited P186,063.42 with Landbank on August 24, 2010, representing one hundred percent of the BIR zonal valuation as alleged compliance with Section 2, Rule 67. The RTC issued a writ placing NGCP in actual possession on July 8, 2011.
Commissioners' Reports and Valuations
The RTC appointed a board of three commissioners who initially submitted a joint commissioner’s report recommending P60.00 per square meter as the fair market value, relying on ocular inspection and nearby deeds of sale and BIR zonal valuation. One commissioner, Atty. Raymundo C. Capistrano, later filed a separate commissioner’s report recommending P300.00 per square meter. Atty. Capistrano justified the higher valuation by reference to local city ordinances and resolutions allegedly reclassifying the area to agri-industrial, and to a cited 2009 DPWH purchase near the subject property at P250.00 per square meter; he also stated that the recommended amount included the market value of improvements.
RTC Proceedings and Decision
The RTC disregarded the joint report and adopted in full Atty. Capistrano’s separate commissioner’s report. In its August 5, 2014 Decision, the RTC awarded respondents P300.00 per square meter, totaling P2,391,910.80, less the earlier deposit of P186,063.42, and ordered NGCP to pay legal interest of six percent per annum from the actual taking on May 16, 2011 until full payment. The RTC also awarded each commissioner P5,000.00 as honorarium. NGCP moved for reconsideration, which the RTC denied on June 17, 2015.
Court of Appeals Proceedings
NGCP lodged an appeal but failed to file an appellant’s brief within the reglementary period. On October 27, 2016, the Court of Appeals dismissed the appeal for failure to file an appellant’s brief under Rule 50, Section 1(e), and the case was struck from the docket. NGCP filed a motion for reconsideration with an attached appellant’s brief, which the CA denied on May 11, 2017.
Issues Raised in the Petition
In its petition for review, NGCP advanced two principal issues: whether the CA erred in not reviewing the appeal on the merits given the alleged grossly unfair RTC award of P300.00 per square meter, and whether the CA abused its discretion by not admitting the belated appellant’s brief and relaxing procedural rules in favor of substantial justice and good faith.
Parties' Contentions
NGCP contended that the joint commissioner’s report was more credible because it relied on ocular inspection and proximate sales data indicating prices near P47.30 to P60.00 per square meter, and that Atty. Capistrano’s separate report lacked factual and legal basis. NGCP also urged that procedural rules should be relaxed because it acted in good faith and did not intend to delay proceedings. The respondents maintained that the CA properly exercised its discretion to dismiss the appeal for failure to file an appellant’s brief.
Legal Standards on Dismissal for Failure to File Brief
The Court reviewed controlling jurisprudence emphasizing that dismissal for failure to file an appellant’s brief is discretionary, not mandatory. The Court reiterated the principles articulated in cases such as Liao Sen Ho v. Philippine Savings Bank and Beatingo v. Bu Gasis: the general rule favors dismissal, yet the appellate court may allow belated filing when circumstances justify leniency, when equity and substantial justice so require, when no material prejudice to the appellee exists, and when the delay is reasonable; mere inadvertence of counsel generally does not suffice except in narrow circumstances such as gross negligence that deprives a client of due process or where liberty or property are at stake.
Determination of Just Compensation
On the merits, the Court held that the ascertainment of just compensation is a judicial function that must rest on reliable and actual data. The Court found that the RTC erred in fully adopting Atty. Capistrano’s separate report because it was not grounded in actual or reliable evidence. The city ordinances and resolutions cited by Atty. Capistrano did not establish a lawful reclassification of the subject lots to agri-industrial, and his cited DPWH sale was not shown to be proximate to the subject property. Conversely, the joint commissioner’s report relied on nearby deeds of sale, BIR zonal valuation, and ocular inspection. Given that remand would further delay payment and accrue additional interest, the Court exercised its discretion to adopt the joint commissioner’s valuation and set just compensation at P60.00 per square meter, for a total of P478,381.56 for the affected area, less the P186,063.42 previously deposited.
Interest and Monetary Award
The Court affirmed that interest on just compensation constitutes forbearance and is properly awarded. It modified the RTC’s interest award by ordering interest at twelve percent per annum f
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Case Syllabus (G.R. No. 232119)
Parties and Procedural Posture
- National Grid Corporation of the Philippines (NGCP) filed a Petition for Review on Certiorari assailing the Court of Appeals Resolutions dated October 27, 2016 and May 11, 2017.
- Getulia A. Gaite and the heirs of Trinidad Gaite, represented by Atty. Eulalio G. Gaite, were the respondents in the eminent domain proceedings below.
- The petition sought reversal of the Court of Appeals' dismissal of NGCP's appeal and modification of the Regional Trial Court decision fixing just compensation at PHP300.00 per square meter.
- The Supreme Court granted the petition and modified the RTC decision as set forth in the disposition of this syllabus.
Key Factual Allegations
- NGCP filed a Complaint for Eminent Domain on April 15, 2010 to acquire the subject properties for the Abaga-Kirahon 230 kV Transmission Line Project.
- The subject parcels comprised Lot No. 3366 with 133,548 square meters and Lot No. 5261 with 118,117 square meters, with the affected areas totaling 7,973.03 square meters.
- NGCP deposited PHP186,063.42 with Landbank on August 24, 2010 equivalent to 100% of the BIR zonal value and obtained a Writ of Possession issued July 8, 2011 placing it in actual possession.
- A Board of Commissioners submitted a joint report recommending PHP60.00 per square meter as fair market value based on ocular inspection and comparable deeds of sale.
- Commissioner Atty. Raymundo C. Capistrano submitted a separate report recommending PHP300.00 per square meter based on asserted reclassification of the area and cited but unimplemented ordinances and a distant DPWH sale.
- The RTC adopted fully Atty. Capistrano's separate report and awarded just compensation at PHP300.00 per square meter less the earlier deposit, plus legal interest and commissioner honoraria.
Procedural History
- The RTC rendered its Decision on August 5, 2014 adopting the separate commissioner's valuation and ordered payment of PHP2,391,910.80 less the deposit of PHP186,063.42, plus interest and honoraria.
- NGCP filed a Motion for Reconsideration which the RTC denied on June 17, 2015.
- NGCP filed a Notice of Appeal but the Court of Appeals dismissed the appeal on October 27, 2016 for failure to file an appellant's brief under Rule 50, Sec. 1(e).
- NGCP sought reconsideration in the Court of Appeals which was denied, and then filed the present Petition for Review on Certiorari before the Supreme Court.
Issues Presented
- Whether the Court of Appeals erred in dismissing NGCP's appeal for failure to file an appellant's brief and in refusing to exercise discretion to admit the belated brief.
- Whether the RTC erred in adopting the separate commissioner's report and in fixing just compensation at PHP300.00 per square meter absent reliable and actual data.
- Whether procedural rules should be relaxed in favor of substantial justice given the circumstances of the case.
Parties' Contentions
- NGCP argued that the joint commissioners' repor