Case Summary (G.R. No. 246565)
Applicable Law and Nature of the Case
The relevant legal framework for this case is grounded in the 1987 Philippine Constitution, particularly focusing on the principles of just compensation in expropriation cases. The petitioners contested the expropriation proceedings initiated by NAPOCOR, which included their claims for fair compensation for the taking of their properties, as well as consequential damages due to the devaluation of their remaining land.
Factual Background
NAPOCOR filed a complaint for expropriation on September 7, 2001, to acquire an easement over the subject lots. Petitioners contended that the market value of their land had significantly increased and that the installation of NAPOCOR's facilities would impair the value of their remaining lots, thereby justifying their claim for consequential damages. NAPOCOR received possession of the properties on December 19, 2003, after paying an initial deposit. A Board of Commissioners was subsequently appointed by the Regional Trial Court (RTC) to ascertain just compensation, valuing the lots at P593.86 per square meter.
Regional Trial Court Ruling
In its January 18, 2010 ruling, the RTC accepted the Board of Commissioners' valuation and included a consequential damages award, reflecting a decline in the market value of the remaining land affected by the expropriation. The RTC granted P26,538,415.68 in consequential damages, asserting that the properties' values would diminish due to the presence of high-tension power lines.
Court of Appeals Decision
On September 18, 2017, the Court of Appeals (CA) affirmed the RTC's valuation for just compensation but found the award for consequential damages to be speculative. The CA removed the attorneys' fees awarded by the RTC and denied the petitioners' claims for legal interest because they had not appealed the RTC's silence on such issues.
Supreme Court's Analysis and Rulings
The Supreme Court identified two key issues: whether the CA erred by remanding the determination of consequential damages and whether it failed to impose legal interest on just compensation. The Court held that the CA erred in dismissing the claim for consequential damages without adequately considering the evidence presented, emphasizing that property owners are entitled to recover for losses in value of the remaining property due to the expropriation.
The Court cited previous case law that established a precedent for awarding consequential damages in such cases, specifically acknowledging the negative market impacts arising from the proximity of power transmission lines. However, the Court also concluded that the CT's specific percentage of 10% for consequential damages lacked sufficient basis and determined that these damages should instead be calculated at 50% of the Bureau of Internal Revenue (BIR) zonal valuation at the time of the complaint filing, ultimately updating the consequential damages to P3,798,480.00.
Legal
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Case Background
- Petitioners are Ricardo S. Schulze, Sr. (now deceased, represented by his wife), Ana Maria L. Schulze, Jose Luis S. Valdes, Spouses Maria Elena S. Valdes and Antonio Valdes, and Elaris Investment Co., Inc.
- Respondents are the National Power Corporation (NAPOCOR) and the Philippine National Bank (PNB).
- The case involves a petition for review on certiorari contesting the CA's decisions affirming the RTC's ruling regarding just compensation for an expropriated property.
Facts of the Case
- NAPOCOR filed a complaint on September 7, 2001, for the expropriation of an easement of right of way over 23,563 sq. m. of land owned by petitioners for a transmission line project.
- Petitioners argued that the value of their land had significantly increased and that the remaining lots would suffer depreciation due to the installation of power lines.
- NAPOCOR received possession of the property on December 19, 2003, after paying P519,851.47, based on the BIR zonal valuation.
- The RTC appointed a Board of Commissioners to determine just compensation, which was set at P593.86/sq. m., totaling P13,993,260.00, with additional consequential damages of P26,538,415.68 awarded for the remaining property.
RTC Rulings
- The RTC adopted the commissioners' findings and established just compensation based on market values and the changing