G.R. No. 223195 - National Transmission Corp. vs. Spouses Taglao

The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
The petitioner is the National Transmission Corporation (TRANSCO), acting as the transferee-in-interest of the National Power Corporation (NPC).
The respondents are spouses Mariano S. Taglao and Corazon M. Taglao.
The petition seeks to nullify the Decision dated December 17, 2015, and the Resolution dated February 22, 2016, of the Court of Appeals (CA), which dismissed NPC's appeal for lack of merit.

TRANSCO is a government entity responsible for the development of hydroelectric power and electricity production.
NPC was authorized by Republic Act No. 6395 to acquire private properties for its projects.
On November 24, 1995, NPC filed a Complaint for Eminent Domain against the Spouses Taglao to acquire an easement of right of way over a portion of their property for the Tayabas-Dasmari 500 KV Transmission Line Project.
The Spouses Taglao owned a 5,143 sq.m. parcel of land, of which 3,573 sq.m. was sought for the easement.

The Spouses Taglao moved to dismiss the eminent domain case, but the RTC denied this motion and granted NPC a Writ of Possession.
The RTC later declared the subject property condemned and directed the parties to submit names of commissioners to determine just compensation.
The commissioners submitted differing reports on the just compensation, with NPC's commissioner recommending P156,690.44 and the Taglaos' commissioner recommending P12,858,000.00.

In its January 13, 2003 Decision, the RTC fixed the market value of the property at P1,000.00 per sq.m., leading to a total just compensation of P509,170.00.
The RTC's calculation was based on the affected area, easement fees, and the value of improvements on the property.
NPC's motion for reconsideration was denied on August 8, 2007.

NPC appealed the RTC's decision to the CA, which affirmed the RTC's ruling in its December 17, 2015 Decision.
The CA denied NPC's motion for reconsideration in a Resolution dated February 22, 2016.
NPC subsequently filed the present petition.

TRANSCO contended that the CA erred in affirming the RTC's ruling, particularly regarding the market value fixed at P1,000.00 per sq.m.
It argued that just compensation should be determined as of the date of the taking or the filing of the complaint, with the filing date being November 24, 1995.
TRANSCO criticized the RTC and CA for basing their calculations on speculation rather than established principles or evidence.

Just compensation is defined as the full and fair equivalent of the property taken, reflecting the owner's loss rather than the taker's gain.
Factors influencing just compensation include acquisition costs, current values of similar properties, and the property's characteristics.
The Court emphasized that just compensation should be based on the fair market value at the time of the filing of the complaint.

The Court found that the valuations submitted by both commissioners were not reflective of the property's market value at the time of the complaint.
The RTC's valuation of P1,000.00 per sq.m. lacked supporting evidence and was deemed speculative.
The CA's justification for affirming this valuation was also found to be speculative and without a reliable basis.