Case Summary (G.R. No. 172238)
Overview of the Legal Proceedings
On October 25, 2006, the Religious of the Virgin Mary filed a Complaint for just compensation and damages against TransCo before the Regional Trial Court in Cagayan de Oro City due to the occupation of a 17,185-square-meter area of their property. TransCo admitted the occupation but contended that the affected area was less and claimed an easement by prescription. The case progressed through various stages, including a court inspection and the evaluation of property valuation reports by appointed commissioners.
Determination of Just Compensation
The Regional Trial Court initially determined in its orders from 2011 to 2014 that just compensation was to be based on the 2006 zonal values, ultimately assessing the value at P1,744,200.00. Following a remand by the Court of Appeals, which ruled just compensation should be based on 2014 valuations, TransCo sought further review. The core dispute revolved around whether just compensation should be reckoned from the date of taking in 1966 or from an advisory later date.
Court's Analysis of Taking
The Supreme Court affirmed the existence of taking in 1966 when the transmission lines were constructed, contradicting the lower courts' findings that delayed acknowledgment of this taking. The Court emphasized that although TransCo came into existence in 2001, it inherited rights and obligations from the National Power Corporation, which originally constructed the line.
Legal Precedent and Reasoning
The Supreme Court cited previous jurisprudence underscoring that just compensation must reflect the property’s value as of the time of taking. It clarified that compensation should not only address property worth but also loss of income potential caused by the property’s occupation. The motion to set compensation based on current values after a significant delay was rejected as it was deemed unjust to penalize the owner by altering the timing for valuation.
Conclusion a
...continue readingCase Syllabus (G.R. No. 172238)
Case Overview
- The case revolves around the issue of just compensation due to the Religious of the Virgin Mary (RVM) from the National Transmission Corporation (TransCo) for the unauthorized construction of transmission lines on a portion of their property.
- The Supreme Court reviews the findings of the Regional Trial Court (RTC) and the Court of Appeals regarding the valuation and timing of just compensation.
Background of the Case
- RVM is the registered owner of a 360,029-square-meter land in Barrio Iponan, Cagayan de Oro City, covered by Original Certificate of Title No. 0-452.
- On October 25, 2006, RVM filed a complaint for just compensation and damages against TransCo, claiming that a 17,185-square-meter portion of their land was taken without consent or expropriation proceedings.
- TransCo acknowledged some occupation of RVM's property but disputed the area affected, asserting it was less than claimed and that it had acquired an easement by prescription.
Proceedings in the Regional Trial Court
- The RTC commissioned a survey, which determined the area affected by the transmission line was 8,721 square meters.
- A series of orders followed, including a directive for TransCo to deposit a provisional amount in fa