Case Summary (G.R. No. 216723)
Factual Background
On March 18, 2004, the DPWH initiated expropriation proceedings for a 550-square meter parcel of land located in Kawit, Cavite, owned by Pacita Villao, to facilitate the Manila-Cavite Tollways Expressway Project. After initially depositing amounts for the land and structures on it, the Regional Trial Court granted a writ of possession and allowed the inclusion of Carmienett Javier as a defendant due to her ownership of the improvements on the property. Subsequent to the proceedings, the RTC established a Board of Commissioners (BOC) to determine just compensation for the expropriated land.
Assessment of Just Compensation
On August 15, 2011, the BOC recommended a compensation rate of P9,000.00 per square meter, considering factors such as location, market data, and comparables from nearby properties. The recommendation was primarily influenced by a previous RTC decision in a similar case (Republic v. Tapawan), wherein properties of similar type and location were valued similarly.
RTC Decision
The RTC ruled in favor of the respondents on October 24, 2011, adopting the BOC's recommended valuation. The total compensation was pegged at P4,950,000.00, ordered an additional payment of P3,905,000.00, and directed legal interest to be calculated from the taking of the property.
CA Ruling and Petitioner’s Appeal
Upon appeal, the CA affirmed the RTC's decision, asserting that the BOC's findings were substantiated by adequate evidence, including site inspections and corroborative materials. The petitioner, however, contended that the BOC report relied heavily on hearsay and lacked solid evidentiary support. The petitioner argued that just compensation should reflect the market conditions at the time of the expropriation complaint's filing, not speculative values from comparable transactions.
Court's Ruling
The Supreme Court found merit in the petitioner’s arguments, particularly regarding the reliance on the BOC’s valuation. It emphasized that just compensation must be determined as of the date of the complaint filing. The amount of P9,000.00 per square meter was deemed inconsistent with legal standards. The Court noted that the commissioners did not adequately demonstrate that the valuation reflected market conditions as of March 18, 2004.
Legal Interest Determination
The Court mandated a remand to the RTC for proper reassessment of just compensation, emphasizing the signifi
...continue readingCase Syllabus (G.R. No. 216723)
Case Overview
- The case involves a Petition for Review on Certiorari by the Republic of the Philippines against respondents Pacita Villao and Carmienett Javier regarding an expropriation proceeding.
- The petition was assailed against the Decision dated July 31, 2014, and the Resolution dated February 4, 2015, of the Court of Appeals in CA-G.R. CV No. 98304.
Factual Antecedents
- On March 18, 2004, the DPWH filed an expropriation complaint for a 550-square meter parcel of land located in Kawit, Cavite, owned by Villao, for the Manila-Cavite Tollways Expressway Project.
- The DPWH sought to amend the complaint to include Carmienett Javier, who owned improvements on the property.
- An initial deposit of P1,045,000.00 for the land and additional amounts for the improvements was made.
- The Regional Trial Court (RTC) issued a Writ of Possession in favor of the DPWH, allowing it to take possession of the property.
- The RTC subsequently allowed respondents to withdraw the deposited amounts for the property and improvements.
- A Board of Commissioners (BOC) was created to determine just compensation, which later recommended P9,000.00 per square meter, based on various factors including market data and a similar case (Republic v. Tapawan).
RTC Ruling
- The RTC ruled in favor of the respondents, adopting the BOC's valuation of P9,000.00 per square meter as just compensation, amounting to P4,950,000.00 for the property.
- The court orde