Case Summary (G.R. No. 207078)
Antecedents and Proceedings
On December 7, 2007, the petitioner filed a complaint for expropriation against the spouses Goloyuco in the Regional Trial Court (RTC) of Valenzuela City. Following the filing, an Urgent Ex Parte Motion for Issuance of Writ of Possession was granted, and the spouses Goloyuco were compensated with a provisional deposit of P137,500.00. The RTC subsequently appointed commissioners to determine just compensation for the property. Various reports were submitted, with differing valuations proposed by the appointed commissioners.
RTC's Findings and Decision
On February 18, 2014, the RTC ruled that the just compensation for the expropriated land should be set at P8,300.00 per square meter, totaling P415,000.00, after considering the zonal valuation and the valuations of similar properties. The RTC emphasized the comprehensive assessment process that factored the location, commercial relevance, and the condition of the property into its valuation.
Court of Appeals' Ruling
The Court of Appeals (CA) upheld the RTC's decision on July 21, 2015, with modifications regarding the legal interest applicable to the just compensation due. It reiterated that the RTC appropriately conducted an independent assessment for just compensation and complied with the requirements of Section 5 of Republic Act No. 8974, which governs the assessment of property value in expropriation cases.
Petitioner’s Argument
The petitioner contended that the CA and RTC erred in fixing just compensation at P8,300.00 per square meter, arguing that it should align with the Bureau of Internal Revenue's (BIR) zonal valuation of P2,750.00. The petitioner raised concerns over potential injustices resulting from higher compensation payments compared to lower zonal valuations leading to unequal tax burdens on the property owners versus the government.
Respondents’ Counterarguments
In response, the spouses Goloyuco highlighted the significant market disparity, presenting evidence that commercial properties in that area commanded much higher prices. They asserted that the just compensation valuation must reflect the actual market conditions rather than solely relying on zonal valuations, as mandated by the law.
Supreme Court’s Ruling
In its ruling, the Supreme Court dismissed the petition, affirming the findings of the lower courts regarding just compensation. It reiterated that just compensation should reflect the fair market value and should not solely depend on the property’s zonal valuation. The Court underscored that factual determinations made by the RTC should generally be upheld, as it adheres to the standards of fairness and equity concerning property expropriation.
Legal Interest Determination
The final ruling
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Case Overview
- The case involves a Petition for Review on Certiorari concerning the decision of the Court of Appeals (CA) affirming with modification the ruling of the Regional Trial Court (RTC) regarding the just compensation for expropriated property.
- The petitioner is the Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH), while the respondents are spouses Pedro and Zenaida Goloyuco, the owners of the land subject to expropriation.
Antecedents
- On December 7, 2007, the DPWH filed a complaint for expropriation against the spouses Goloyuco for their 50 square meter parcel of land in Barangay Ugong, Valenzuela City, intended for the C-5 Northern Link Road Project.
- Following procedural steps, including a motion for the issuance of a Writ of Possession, the RTC ordered the payment of P137,500.00 as provisional compensation based on the zonal valuation.
- After the compensation was paid, the court appointed commissioners to assess the just compensation, with varying recommendations among them ranging from P10,000.00 to P12,250.00 per square meter.
RTC Ruling
- The RTC determined the just compensation at P8,300.00 per square meter, totaling P415,000.00, after considering various factors in