Case Summary (G.R. No. 179334)
Applicable Law
1987 Constitution, Article III, Section 9 (private property shall not be taken for public use without just compensation); statutory rules on expropriation and jurisprudential definitions of “just compensation.”
Facts
In 1940, the government constructed the MacArthur Highway over the Tecsons’ land without expropriation proceedings or owner consent. In December 1994 the Tecsons demanded fair compensation; the DPWH offered ₱0.70/sqm based on a 1950 Provincial Appraisal Committee (PAC) rate. The Tecsons rejected that offer and, in March 1995, filed an accion reivindicatoria with damages, claiming a current market valuation of ₱2,543,800.
Procedural History
– RTC (Branch 80, Malolos): Dismissed the complaint on state-immunity grounds (June 28, 1995).
– CA (G.R. CV No. 51454): Reversed the dismissal, held immunity inapplicable to a compensation claim, and remanded for just-compensation determination (February 11, 1999).
– PAC of Bulacan: Inspected the land and recommended ₱1,500/sqm as just compensation (Resolution No. 99-007, December 19, 2001).
– RTC Decision (March 22, 2002): Ordered DPWH to pay ₱1,500/sqm.
– CA Decision (July 31, 2007): Affirmed the ₱1,500/sqm award, adding 6% annual interest from March 17, 1995.
– Supreme Court: Petition for review on certiorari under Rule 45.
Issues Presented
- Whether respondents’ ownership or title is dubious and bars compensation.
- Whether the complaint is barred by prescription or laches.
- Whether just compensation must be based on current market value or on the value at the time of taking.
Supreme Court Ruling
The petition is PARTIALLY GRANTED. The CA decision is modified as follows:
• Valuation of the subject property is fixed at ₱0.70 per square meter (value at the time of taking in 1940).
• Interest at six percent per annum runs from the date of taking in 1940 until full payment.
Reasoning
– Ownership and Title: The CA’s 1999 decision settling respondents’ entitlement to compensation is the law of the case; collateral attack on their Torrens title is impermissible.
– Prescription and Laches: Not proper issues because they were omitted from the pre-trial order. Even on the merits, no prescription attaches to a claim for compensation when property was taken without expropriation proceedings; laches does not apply where no inequity results from entertaining the claim.
– Basis for Just C
Case Syllabus (G.R. No. 179334)
Facts
- Respondents are co-owners of a 7,268 sqm parcel in San Pablo, Malolos, Bulacan (TCT No. T-43006).
- In 1940 the government took the land without expropriation proceedings or owners’ consent to build MacArthur Highway.
- By letter dated December 15, 1994 respondents demanded fair-market compensation; DPWH District Engineer Contreras offered ₱0.70/sqm per a 1950 PAC resolution.
- Respondents rejected the offer, claimed the land was worth ₱2,543,800, and sought return of possession or current‐value compensation.
Procedural History
- March 1995: Complaint for recovery of possession with damages filed in RTC, Civil Case No. 208-M-95.
- June 1995: RTC granted petitioners’ motion to dismiss for state-immunity; appeal to CA (docketed CA-G.R. CV No. 51454).
- July 31, 2007: CA in CA-G.R. CV No. 77997 affirmed RTC decision awarding ₱1,500/sqm, added 6% p.a. interest from March 17, 1995.
- Supreme Court grant of petition for review on certiorari under Rule 45, raising ownership, prescription and laches, and valuation issues.
Issues
- Whether respondents’ ownership of the subject parcel is sufficiently established.
- Whether respondents’ action is barred by prescription or laches.
- Whether just compensation must be based on 1940 value