Case Summary (G.R. No. 190147)
Applicable Law
The proceedings are governed by the 1987 Philippine Constitution on eminent domain, as the decision date is November 11, 2008.
Procedural Background
The PNOC initiated two separate expropriation actions in 1994 against the Maglasang brothers, with Civil Case No. 3267-O for Lot No. 11900 and Civil Case No. 3273-O for Lot No. 11907. Following judicial proceedings, the Regional Trial Court (RTC) of Ormoc City granted writs of possession for both lots and subsequently appointed commissioners to determine just compensation.
Commissioners’ Valuations
The commissioners presented differing valuations for the properties: City Assessor Briccio D. Supremo suggested ₱1,000.00 per square meter; RTC Clerk of Court Bibiano Reforzado recommended ₱900.00; and businessman Augusto T. Pongos valued the lots at ₱400.00 and ₱85.00 per square meter for developed and undeveloped areas, respectively. The RTC settled on an initial valuation of ₱300.00 per square meter, later modified to ₱700.00 per square meter to account for inflation and adjustment factors.
Court of Appeals Decision
Upon appeal, the Court of Appeals (CA) modified the trial court's ruling, reducing the just compensation to ₱300.00 per square meter. It found that the trial court erred in applying inflation and adjustment factors, asserting that compensation should reflect the actual loss suffered by the property owner at the time of expropriation.
Just Compensation Principles
The appellate court emphasized that just compensation is based on the actual value of land at the time of taking, and not augmented by inflation or other economic factors. Thus, they reiterated that the compensation reflects what the property owner truly loses.
Petitioner’s Arguments
The PNOC challenged the CA's decision, arguing that the trial court's valuation of ₱300.00 per square meter lacked evidence and that the properties were misclassified as industrial rather than agricultural land at the time of expropriation. The petition also maintained that compensation should be estimated from the time of possession rather than the filing date.
Determination of Taking
However, it was affirmed that "taking" occurred at the moment the property was legally expropriated, following the filing of the complaint. The Supreme Court concurred that prior possession under a lease agreement with the Maglasangs did not constitute a constitutional taking.
Classification of Land
PNOC's assertion regarding the agric
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Case Information
- Court: Supreme Court of the Philippines
- Date: November 11, 2008
- G.R. No.: 155407
- Division: First Division
- Petitioner: Philippine National Oil Company (PNOC)
- Respondents: Leonilo A. Maglasang and Oscar S. Maglasang
Background of the Case
- The case involves a petition for review on certiorari concerning the January 23, 2002 Decision of the Court of Appeals (CA) in CA-G.R. CV No. 67341.
- The CA's decision modified the Joint Judgment dated December 16, 1999, of the Regional Trial Court (RTC) of Ormoc City in Civil Case Nos. 3267-O and 3273-O.
- The case arose from the complaints for eminent domain filed by PNOC against the respondents, who were the owners of two parcels of land in Kananga, Leyte.
Eminent Domain Complaints
- On October 25, 1994, PNOC filed a complaint against Oscar S. Maglasang for a 63,333-square meter parcel of land (Lot No. 11900).
- On November 10, 1994, PNOC filed a similar complaint against Leonilo A. Maglasang for a 98,206-square meter parcel (Lot No. 11907).
- The lands were intended for the construction and operation of the 125MW Upper Mahiao Geothermal Power Plant Project.
Proceedings in the RTC
- The RTC issued writs of possession for both lots after PNOC posted a provisional deposit.
- On March 21, 1997, commissioners were appointed to ascertain just compensation for the condemned properties.
- The commissioners submitted a report with varying valuations:
- City Assessor recommended P 1,000.00 per square meter.
- Clerk of Court valued it at P 900.00 per square meter.
- Businessman arrived at P 400.00 per square meter for developed land and P 85.00 for undeveloped land.
Trial Court's Decision
- The t