Case Summary (G.R. No. 143643)
Procedural History
This matter is a petition for review of a decision rendered by the Court of Appeals dated June 16, 2000, which affirmed the ruling of the Regional Trial Court (RTC) of Quezon City. The RTC had ordered the NPC to pay the respondents a total of P1,980,000, comprising actual, moral, and nominal damages due to the unauthorized use and continued intrusion on the respondents' property.
Factual Background
The dispute began in the mid-1970s when Dr. Paulo C. Campos, brother of respondent Jose C. Campos Jr., requested the respondents to allow NPC to install temporary wooden electric posts and transmission lines on their property for the electrification of Puerto Azul. Respondents granted permission based on assurances that the installation would be temporary. However, NPC continued to occupy the property without compensation. Over the years, NPC's agents trespassed on the property for various purposes and even attempted to engage in expropriation proceedings without the respondents' consent.
Claims and Counterclaims
The respondents filed a complaint against NPC claiming actual damages for the unauthorized use of their property, as well as moral and nominal damages, alleging NPC undertook actions that violated their rights. NPC, in its defense, claimed that it had acquired an easement by prescription due to continuous use since the 1970s and insisted that the respondents had waived their right to seek compensation based on its charter, Republic Act No. 6395.
Trial Court Findings
The RTC found in favor of the respondents, asserting that NPC's utilization of the respondents' property was unauthorized and that there was no valid acquisition of rights through prescription. The court highlighted that NPC's actions constituted trespass and that it had not complied with the legal requisites for the exercise of eminent domain.
Court of Appeals Ruling
The Court of Appeals upheld the RTC's findings, particularly emphasizing that the respondents' right to seek compensation had not lapsed since NPC did not establish any legal basis for its entry and continued use of the property. The CA dismissed NPC's claims regarding prescription and reiterated that no valid negotiations had occurred between the parties regarding compensation for the easement.
Legal Principles Applied
The decisions relied significantly on the 1987 Philippine Constitution, which safeguards property rights and mandates that no private property may be taken for public use without just compensation. The Court reiterated principles around the concepts of easement and prescription as governed under the Civil Code, declaring that mere permissive use of property does not convert into rights without the express consent of the owner.
Damages Awarded
The RTC's award of damages was supported by findings of injury suffered by the respondents due to NPC's actions. The CA recognized the moral and nominal damages awarded as justified and reasonable because NPC's actions were deemed to have caused significant reputational harm and emotional distress to the resp
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Case Overview
- This case concerns a petition for review filed by the National Power Corporation (NPC) against the decision of the Court of Appeals dated June 16, 2000.
- The Court of Appeals affirmed the judgment of the Regional Trial Court (RTC) of Quezon City, which ordered NPC to pay damages totaling P1,980,000 to respondents Spouses Jose C. Campos, Jr. and Ma. Clara A. Lopez-Campos.
Background of the Case
- On February 2, 1996, the respondents filed a complaint against NPC for sum of money and damages.
- The respondents claimed ownership of a 66,819 square meter parcel of land in Bo. San Agustin, Dasmariñas, Cavite, covered by Transfer Certificate of Title No. T-957323.
- In the mid-1970s, Dr. Paulo C. Campos requested NPC to install temporary wooden electric posts for electrification but assured it would be a temporary measure.
- NPC continued to use the property without compensating the respondents and allegedly trespassed during a survey in 1994.
- After refusing permission for further surveys and being misrepresented by NPC agents, the respondents were surprised by NPC’s expropriation case filed in December 1995.
Allegations by the Respondents
- The respondents alleged they were unaware of NPC’s intentions to expropriate their property before they sold it to Solar Resources, Inc.
- They argued that NPC's actions were whimsical, capricious, and violated their rights to due process and equal protection.
- The respondents sought actual, moral, and nominal damages, along with attorney's fees and costs of suit.