Case Summary (G.R. No. 221624)
Applicable Law
The expropriation proceedings and just compensation issues are governed by the provisions of the 1987 Philippine Constitution and Republic Act No. 8974, which facilitates the acquisition of right-of-way for government infrastructure projects.
Expropriation Complaint and Procedural History
On 28 February 2002, NAPOCOR initiated expropriation proceedings against Maria Teresa Lacson De Leon for the acquisition of a parcel of land measuring 39,347 square meters in Barangay Vista Alegre. The intention was to secure a right-of-way for the Bacolod-Cadiz 138 KV SC/ST Transmission Line. Respondents, claiming to be the rightful owners of the property, filed a motion to dismiss contending that the expropriation lacked a public use justification. After procedural adjustments, including amending the complaint to include other parties, the trial court allowed for the expropriation under certain conditions, setting the stage for subsequent evaluations of compensation.
Findings by the Board of Commissioners
The board of commissioners, tasked with evaluating the fair market value of the property, highlighted that the land was classified as residential, despite prior tax declarations that designated it as agricultural. They recommended a compensation rate of PhP722.50 per square meter, grounded in comparisons with similar properties in the area. Nonetheless, they also noted substantial consequential damages due to diminished buyer interest related to high-voltage transmission lines crossing the property, estimating that approximately one-third of the land value was adversely affected.
Trial Court's Decision
The trial court, upon analyzing the board's report, concluded that just compensation should include the recommendations of the board while acknowledging consequential damages amounting to PhP22,463,103.00. The court ordered NAPOCOR to pay a total of PhP28,428,207.50 for the property and the consequential damages along with attorney's fees.
Court of Appeals Ruling
The Court of Appeals modified the trial court's decision, affirming the just compensation figure while deleting the attorney's fees awarded. It mandated the imposition of a 12% interest on the compensation amount from the date of actual possession. The appellate court's ruling emphasized adherence to legal precedent while recognizing the financial and infrastructural implications of the expropriation.
Issues and Legal Analysis
The critical questions before the Supreme Court revolved around the sufficiency of factual evidence supporting the compensation decidements, justifications for consequential damages, and the applicability of interest rates. The court observed that while the findings of the lower courts are generally upheld, discrepancies in how just compensation was determined required rectification.
Ruling of the Supreme Court
The Supreme Court concluded that while the compensation rate initially proposed by the board lacked substantiation, the earlier val
...continue readingCase Syllabus (G.R. No. 221624)
The Case
- The petition for review on certiorari challenges the Decision dated November 12, 2014, and Resolution dated November 18, 2015, in CA-G.R. CV No. 02423.
- The core issue revolves around the determination of just compensation in a special civil action for expropriation.
- The Court of Appeals modified the Regional Trial Court's (RTC) decision, ordering NAPOCOR to pay:
- Just compensation amounting to PhP28,428,207.50, with interest at 12% per annum from February 2, 2004, until full payment.
- Consequential damages totaling PhP22,463,103.00.
Antecedent Facts
- On February 28, 2002, NAPOCOR filed an expropriation complaint against Maria Teresa Lacson De Leon for a 39,347 square meter parcel of land in Bacolod City.
- The intended purpose was to acquire an easement of right-of-way for the Bacolod-Cadiz 138 KV SC/ST Transmission Line.
- Maria Teresa Lacson De Leon filed a Motion to Dismiss on March 20, 2002, arguing that her nine children were the actual owners of the property.
- The trial court directed NAPOCOR to amend its complaint to include the real parties-in-interest.
- NAPOCOR's motion to drop Maria Teresa as a party was granted on October 15, 2002.
- Respondents filed answers disputing the public use and the