Case Summary (G.R. No. 147009)
Factual Antecedents
The Bautista spouses were the registered owners of a 1,893-square meter parcel of land covered by Transfer Certificate of Title No. 41750. In 2000, the DPWH acquired a 36-square meter portion of this property for the Southern Tagalog Arterial Road (STAR) project at a price of P1,300.00 per square meter. Subsequently, the DPWH sought to acquire an additional 1,155 square meters for the Balete-Lipa City Interchange Ramp B, offering P100.00 per square meter, which was rejected by the respondents. The DPWH then filed a Complaint for expropriation in 2004, asserting that the fair value of the property for expropriation purposes was P100.00 per square meter according to the Bureau of Internal Revenue (BIR).
Expropriation Proceedings
Upon onset of the expropriation proceedings, the Bautista spouses passed away, leading to their substitution by the respondents in the case. The respondents challenged the proposed valuation, asserting that previous sales of the same property indicated a higher market value. The trial court authorized the petitioner to take possession of the land after a deposit of P115,500.00 was made. A panel of commissioners was established to determine just compensation, issuing reports that ultimately influenced the trial court's valuation of the property.
Joint Commissioners' Reports
The court received two important reports: one from the Lipa City Assessor and the Registrar of Deeds and another from Mecate, a DPWH special agent. The former concluded that just compensation should range between P1,960.00 and P2,500.00 per square meter, considering the vicinity's market value and recent sales data. The latter's report suggested much lower values, focusing solely on tax declarations and the BIR zonal valuation, leading to criticism over its lack of contextual consideration.
Ruling of the Regional Trial Court
On August 18, 2005, the trial court fixed just compensation at P1,960.00 per square meter, amounting to P2,263,800.00, which included interest from the time DPWH took possession of the property. The trial court endorsed the Joint Commissioners' Report that reflected fair market value considerations, firmly dismissing the lower valuation proposed by Mecate.
Ruling of the Court of Appeals
The Court of Appeals (CA) affirmed the trial court’s decision, maintaining that the trial court properly evaluated fair market value based on multiple factors, including the previous higher sale price of a smaller property portion and appreciating land values due to urban development. The CA ruled that the Just Compensation was legally justified and noted that the respondents deemed the P1,960.00 valuation fair.
Petitioner’s Arguments
The petitioner contended that the CA erred in affirming the trial court’s valuation, arguing that the Joint Commissioners' Report overlooked critical statutory valuation factors outlined in Republic Act No. 8974. The petitioner maintained that the failure to consider these factors resulted in an inflated valuation. Furthermore, they claimed that the property’s supposed agricultural classification warranted a lower compensation range.
Respondents' Counterarguments
In their response, the respondents defended the trial court's valuation as reasonable and supported by evidence. They asserted that the assessment of value encompasses more than merely looking at tax declarations or BIR zonal valuations; the property’s condition and its evolving market context were appropriately considered.
The Court’s Ruling
The Supreme Court upheld the earlier rulings, clarifying that fact
...continue readingCase Syllabus (G.R. No. 147009)
Introduction
- The case revolves around the expropriation of a 1,155-square meter portion of land owned by the spouses Bautista, now claimed by their heirs.
- The petitioner, represented by the Department of Public Works and Highways (DPWH), seeks to acquire the land for infrastructure purposes, specifically for the Balete-Lipa City Interchange Ramp B.
- The primary issue is the determination of just compensation for the land taken under eminent domain.
Factual Antecedents
- The registered owners of the property, Pedro Bautista and Valentina Malabanan, owned a 1,893-square meter lot in Lipa City.
- In 2000, the DPWH purchased a 36-square meter portion of the lot for P46,800.00, or P1,300.00 per square meter.
- The DPWH later attempted to buy an additional 1,155-square meter portion of the lot at a significantly lower price of P100.00 per square meter, which the spouses Bautista refused.
- Following the refusal, the DPWH filed a complaint for expropriation in 2004, leading to legal proceedings.
Expropriation Proceedings
- The trial court authorized the DPWH to take possession of the property after the deposit of P115,500.00.
- A panel of commissioners, including local officials and a DPWH representative, was established to ascertain just compensation.
- Two reports were generated: one from the local assessors valuing the land at P1,960.00 per square meter and another from the DPWH representative, suggesting much lower values.
Ruling of the Regional Trial Court
- On August 18, 2005, the trial court determined just compensation at P1,960.00 per square meter for the