Case Summary (G.R. No. 193455)
Applicable Law
The governing law in this case includes Republic Act (R.A.) No. 6395, which established the NPC, alongside provisions governing eminent domain and just compensation under the 1987 Philippine Constitution. Additionally, recent regulations from the Bangko Sentral ng Pilipinas regarding interest rates apply to the resolution of monetary compensation issues.
Facts of the Case
On February 10, 1995, NPC filed a complaint for the expropriation of 67,984 square meters of land covered by Original Certificate of Title No. P-8665, which is registered under the name of Gregoria Ramoran, as part of its Sual Coal-Fired Thermal Power Plant project. Subsequently, a notice of taking possession was issued, and a deposit of ₱2,030 was made as the assessed value of the property. Procedural motions for intervention were filed by the intervenors, asserting their claims over the property. However, it was subsequently established that the actual area of the land was 91,212 square meters. The Regional Trial Court (RTC) ruled for just compensation at ₱10 per square meter.
Procedural History
The trial court established the compensation amount of ₱10 per square meter for the entire area involved. A partial compromise agreement was executed in 2000, addressing the compensation for the initially claimed area of 67,984 square meters. The RTC later ordered payment for the remaining unclaimed portion of 23,228 square meters, including interest at 12% per annum from February 10, 1995, until full payment.
Issues Raised
The central issue contested by NPC was whether the legal interest on the compensation provided should be set at 6% instead of 12%, as found by the lower courts. NPC contended that the nature of the expropriation did not equate to a loan or forbearance of money, and therefore the lower interest should apply.
Court's Ruling
The Supreme Court upheld the RTC and Court of Appeals' decision, affirming the imposition of 12% interest on just compensation from the date of possession (March 2, 1995) until June 30, 2013, followed by a reduction to 6% thereafter in line with the Monetary Board’s Circular. The Court established that, based on established jurisprudence, the nature of the transacti
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Case Overview
- This case revolves around a Petition for Review on Certiorari filed by the National Power Corporation (petitioner) challenging the Court of Appeals (CA) decision in CA-G.R. CV No. 90778.
- The CA's decision affirmed the Regional Trial Court (RTC) Branch 38's ruling which imposed legal interest at 12% per annum from the filing of the complaint until full payment for the just compensation owed to the respondents.
Parties Involved
- Petitioner: National Power Corporation, a government-owned and controlled corporation established under Republic Act No. 6395.
- Respondents: Heirs of Gregorio Ramoran, represented by Delfin R. Pineda and others.
- Intervenor-Respondents: Spouses Arnulfo R. Versoza and Priscilla M. Versoza; Spouses Domingo and Dominga Gomez; Erlinda Gomez-Ocay, representing other family members.
Facts of the Case
- On February 10, 1995, the petitioner filed a complaint for eminent domain against the respondents for the expropriation of 67,984 square meters of land in Barangay Pangascasan, Sual, Pangasinan, covered by Original Certificate of Title No. P-8665.
- The property was intended for the Sual Coal-Fired Thermal Power Plant project.
- The petitioner deposited P2,030, the assessed value of the property, with the Philippine National Bank and issued a Not