Case Summary (G.R. No. L-24670)
Antecedent Facts
Rosario Rodriguez Reyes, the private respondent, is the absolute owner of a property in Cagayan de Oro City. On November 6, 1990, the DPWH sought permission to enter and construct a road on a portion of her lot, later taking possession of 663 square meters of her land on December 20, 1990, without initiating any expropriation proceedings. Following this, Reyes expressed her objection to this taking through letters to the DPWH. After rejecting the City Appraisal Committee’s valuation of the property, Reyes filed a complaint in March 1992 seeking just compensation and damages from the government.
Trial Court Proceedings
The Regional Trial Court (RTC) of Cagayan de Oro City appointed three commissioners to assess the fair market value of the property. Their initial valuation suggested high market prices per square meter for the land based on its strategic location. The RTC subsequently issued a decision in June 1995, ordering the DPWH to compensate Reyes not only for the land taken but also for damages and attorney's fees. An amended decision followed, adjusting the compensation due to a revised understanding of the area taken.
Court of Appeals Ruling
The Court of Appeals modified the RTC’s judgment, identifying ambiguities regarding the basis of the RTC’s valuation of just compensation. The appellate court emphasized the need for reconvening the commissioners or appointing new ones to ascertain the proper value of the property taken, as well as to assess consequential damages for the remaining land. The appellate court invalidated the RTC’s order to return a portion of the land taken, asserting that the property was no longer available since it became part of the road.
Issues Raised by Petitioner
The DPWH contested the appellate court's decision, specifically questioning the necessity of remanding the case for new valuation and the appropriateness of attorney's fees awarded to Reyes. The DPWH argued that no consequential damages were warranted for the remaining lot, as it remained in Reyes’ possession.
Supreme Court Ruling
The Supreme Court upheld the Court of Appeals' ruling, affirming that the initial taking of property was done without adhering to expropriation protocols. The court reiterated the principles regarding just compensation under the 1987 Philippine Constitution, emphasizing that just compensation must reflect the fair market value at the time of the taking. The court found the remand necessary due to insufficient clarity in the RTC’s decision about the basis for determining just compensation.
The Supreme Court clarified that awarding consequential damages for the remaining portion of the property was justifie
...continue readingCase Syllabus (G.R. No. L-24670)
The Case
- This case involves a petition for review by the Republic of the Philippines, through the Department of Public Works and Highways (DPWH), challenging the Decision of the Court of Appeals dated November 15, 2002, and its Resolution dated September 17, 2003, in CA-G.R. CV No. 50358.
- The Court of Appeals affirmed with modifications the Amended Decision of the Regional Trial Court (RTC) of Cagayan de Oro City, Branch 19.
Antecedent Facts
- Rosario Rodriguez Reyes, the private respondent, is the absolute owner of a parcel of land designated as Lot 849-B, covered by TCT No. T-7194, measuring 1,043 square meters, located on Claro M. Recto and Osmeña Streets, Cagayan de Oro City.
- On November 6, 1990, DPWH requested permission to enter 663 square meters of Reyes's land to begin construction of the Osmeña Street extension road.
- DPWH took possession of the property without initiating expropriation proceedings on December 20, 1990.
- Reyes objected to the taking through letters sent on January 4 and 7, 1991, and rejected the City's appraisal on May 16, 1991, requesting a reappraisal which was denied.
- On March 17, 1992, Reyes filed a complaint in the RTC seeking just compensation and damages.
- The RTC appointed three commissioners to determine the fair market value of the expropriated property and any consequential damages.
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