Case Summary (G.R. No. 226021)
Applicable Law
The applicable law for this case is governed by the 1987 Philippine Constitution, particularly the provisions relating to the taking of property for public use, as well as Republic Act No. 8974, which provides guidelines for expropriation proceedings.
Background and Initial Proceedings
On February 8, 2008, the petitioner filed a complaint for expropriation against the respondents, claiming that the property was needed for a government infrastructure project. A Development Bank of the Philippines check amounting to P413,418.54 was deposited to compensate the respondents, who later moved for the release of a balance which turned out to be required to meet the full zonal value of the property.
Board of Commissioners' Valuation
The Regional Trial Court (RTC) constituted a Board of Commissioners to determine just compensation. The petitioner argued for a valuation of P2,750.00 per square meter based on zonal value. In contrast, the respondents contested this, seeking P10,000.00 to P15,000.00 per square meter based on prevailing market values in a high-intensity commercial zone. The Board ultimately recommended P10,000.00 as just compensation.
RTC's Ruling
The RTC, in its decision dated December 12, 2013, set the just compensation at P9,000.00 per square meter for a total of P468,000.00, after deducting the initial deposit. It directed the payment of interest on this amount and denied additional claims for improvements on the property due to lack of substantiated evidence.
Court of Appeals (CA) Decision
The petitioner appealed the RTC's decision regarding the compensation amount and interest. The CA upheld the RTC's valuation, finding it anchored in relevant considerations, particularly the proximity and context of the property compared to recently settled cases. The CA reaffirmed that zonal valuation alone does not determine just compensation.
Issues Presented
The main issue in question was whether the CA erred in sustaining the RTC's valuation of just compensation. The petitioner contended that relevant factors had not been appropriately considered while asserting that the expropriated land was situated in an area with informal settlers, thus warranting a lower compensation.
Legal Principles and Rulings
The Supreme Court defined just compensation as the fair market value of the property at the time of taking. It recognized that the determination of this value requires judicial evaluation of reliable evidence and is deemed a question of fact, not typically reviewable by the Supreme Court. Since the factual findings of the RTC were affirmed by the CA, they were binding, and the Court found no compelling reason to disturb the decisions made below.
Final Rulings on Interest
The Supreme Court modified the CA's ruling on interest rates, clarifying that no interest
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Overview of the Case
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petition is directed against the Decision dated December 17, 2015, and Resolution dated July 21, 2016, of the Court of Appeals (CA) in CA-G.R. CV No. 102216.
- The petitioner is the Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH), while the respondents are Gilda A. Barcelon, Harold A. Barcelon, and Hazel A. Barcelon.
Factual Background
- The Republic of the Philippines, through DPWH, filed a complaint for expropriation on February 8, 2008, for a parcel of land owned by the respondents.
- The property is located in Barangay Ugong, Valenzuela City, and is covered by Transfer Certificate of Title No. V-75179, measuring 52 square meters.
- The zonal value of the property was set at P2,750.00 per square meter, while the residential improvement on the property was valued at P288,418.54.
- A manager's check for P413,418.54 was deposited by the petitioner, which was received by the respondents on November 21, 2008.
- The initial amount was found to be P18,000.00 short of the required 100% zonal value, resulting in the RTC ordering the release of this balance to the respondents.
Proceedings Before the Board of Commissioners
- A Board of Commissioners was constituted to determine the just compensation for the property.
- The petitioner cited the zonal valuation and the poor conditions of the area, claiming the just compensation should not exceed the zonal value.
- The respondents argued for a valuation of P10,000.00 to P15,000.00 per square meter based on the pro