Case Summary (G.R. No. 107159)
Procedural Background
On July 22, 1996, NPC filed a complaint for eminent domain against Villamor regarding his properties in Cantipay, Carmen, Cebu, identified as Lot 3 and Lot 4 of 6191 Cad. 1046-D. NPC initially deposited P23,115.70 representing the assessed value of the lands and eventually, the Regional Trial Court of Danao City ordered the issuance of a writ of possession in favor of NPC on July 14, 1997. Several heirs of Villamor intervened in the case, arguing that NPC violated their rights by negotiating exclusively with Villamor.
Valuation Process
The trial court appointed a board of commissioners to determine just compensation for Villamor's lands, which ultimately recommended a fair market value of P433 per square meter based on several factors including inspections, documentary evidence, and market analyses. Villamor contested the valuation and provided evidence of a similar expropriation case where a higher compensation of P450 per square meter had been awarded.
Trial Court Decision
On December 22, 1997, the trial court ruled in favor of Villamor, determining that the just compensation should be P450 per square meter for the expropriated lands, alongside compensation for the improvements on those lands. Following Villamor’s motion for reconsideration regarding a small portion of Lot 4, the court amended its decision to include compensation for that part as well.
Court of Appeals Ruling
NPC appealed the trial court's decision to the Court of Appeals, which affirmed the lower court's ruling on August 19, 2002. The appellate court reasoned that the trial court had properly considered multiple factors in arriving at the just compensation amount of P450 per square meter. It dismissed NPC's claims that it only acquired an easement of right of way, noting that the actual use of Villamor's lands was permanently impaired due to the installation of transmission lines and a tower.
Legal Issue Presented
The core issue for resolution was whether the fair market value awarded by the trial court might be reduced based on claims that only an easement, rather than outright ownership, was being acquired by NPC. NPC contended that since the lands were classified as agricultural and lacked commercial activity, the compensation was excessive.
The Court'
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Case Overview
- The case involves a petition for review filed by the National Power Corporation (NPC) contesting the Decision dated August 19, 2002, and the Resolution dated August 28, 2003, of the Court of Appeals in CA-G.R. CV No. 61749.
- The primary issue pertains to the expropriation of certain lands owned by Carlos Villamor, which were necessary for NPC's Leyte-Cebu Interconnection Project.
Parties Involved
- Petitioner: National Power Corporation (NPC) - a government-owned and controlled corporation established under Republic Act No. 6395, tasked with the development of hydro-electric generation and power production.
- Respondent: Carlos Villamor - the landowner whose properties are subject to expropriation by NPC.
Relevant Facts
- NPC's project required the installation of 230 KV transmission lines and towers that would traverse Villamor's lands located in Cantipay, Carmen, Cebu.
- Villamor's lands included various fruit-bearing and non-fruit-bearing trees, which were part of the property being expropriated.
- On July 22, 1996, NPC initiated an eminent domain complaint in the Regional Trial Court (RTC), seeking to acquire Villamor's lands, identified by specific titles and areas.
- NPC deposited an initial amount for the assessed value of the properties with the Philippine National Bank.
Legal Proceedings
- The RTC authorized NPC to take possession of the lands and a