Case Summary (G.R. No. 157847)
Applicable Law
This case is governed by the provisions relating to eminent domain under the 1987 Philippine Constitution, particularly Article III, Section 9, which mandates prompt payment of just compensation for properties taken for public use.
Background of the Case
In 1956, the ATO took control of a 4,901 square-meter portion of Lot 6068, which was initially used as an airport parking area. Over time, various structures such as the airport control tower and terminal were built on it. In 1997, private respondents initiated a Recovery of Possession with Damages, leading to the ATO filing for expropriation of the entire Lot 6068 in 1998. A trial court eventually determined just compensation for the occupied portion in a decision dated November 26, 1999, prompting appeals from the ATO regarding the amount fixed.
Summary of Trial Court's Findings
The Regional Trial Court determined the just compensation for the 4,901 square-meter property at P800.00 per square meter based on its current market value as of November 11, 1999, the date the writ of possession was issued. The court relied on the rationale that the "taking" must be considered at the time of possession by the government, and not at the time of initial possession in 1956.
Court of Appeals Ruling
The Court of Appeals affirmed the trial court’s decision, emphasizing the ATO's failure to adequately prove that the taking occurred in 1956 and questioning the nature of possession at that time as an expropriation. The appellate court concluded that the just compensation should be evaluated based on the time of the writ of possession, indicating that mere physical occupation did not suffice as legal "taking" for expropriation purposes.
Supreme Court's Analysis of Just Compensation Timing
The Supreme Court assessed whether just compensation should be determined at the time of taking by the expropriating entity in 1956 or the issuance of the writ of possession in 1999. It determined that the evidence was sufficient to prove ATO's possession began in 1956, which is critical for establishing when the taking occurred.
Conclusion on Just Compensation
The Supreme Court held that the just compensation for the 4,901 square-meter property should be based on its value in 1956, contradicting the decision of both the trial court and the Court of App
...continue readingCase Syllabus (G.R. No. 157847)
Case Overview
- The case involves a petition for review on certiorari under Rule 45, challenging the decision of the Court of Appeals dated November 18, 2002, which upheld the decision of the Regional Trial Court of Aklan.
- The dispute centers around the expropriation of a 4,901 square-meter portion of Lot 6068, located in Pook, Kalibo, Aklan, originally owned by the respondents, heirs of Segundo De la Cruz.
Background Information
- The Air Transportation Office (ATO) took possession of the 4,901 square-meter portion in 1956 and initially used it as an airport parking area.
- Over the years, several structures were built on this land, including an airport control tower, a crash fire rescue station, and a terminal.
- In 1995, private respondents filed a complaint for Recovery of Possession with Damages against ATO, which intervened by asserting that the occupants of nearby stores were its lessees.
Legal Proceedings
- On June 25, 1998, the ATO filed for expropriation of Lot 6068, which led to the trial court appointing three commissioners to determine the just compensation.
- The commissioners recommended a compensation of P800.00 per square meter for the 4,901 square-meter portion and P500.00 for the remaining unoccupied area.
Trial Court's Ruling
- The Regional Trial Court,