City Government of Toledo City v. Fernandos
REITERATIONFacts
The Antecedents: This case concerns an expropriation proceeding initiated by the City Government of Toledo City to acquire several parcels of land for the extension of Poloyapoy Street. The City Government deposited P33,060.00 with the Philippine National Bank as an initial payment. The underlying dispute centers on the determination of just compensation for the private respondents' properties. Procedural History: The expropriation case was filed by the City Government of Toledo City. A pre-trial conference was held before the respondent judge, Honorable Judge Pio Fernandos of the CFI, Cebu, with all parties present. Based on the proceedings and evidence presented during the pre-trial, the respondent judge rendered a decision on October 6, 1975, setting the just compensation for the expropriated properties. The petitioner alleges that the respondent judge committed grave abuse of discretion and acted without jurisdiction when denying its motion for reconsideration, issuing a writ of execution, and subsequently garnishing the petitioner's deposit. The Petition: The City Government of Toledo City filed this petition for certiorari and mandamus, seeking to nullify the decision of the Court of First Instance of Cebu. The petitioner argues that the respondent judge erred in determining the just compensation, contending that the appraisal should have been based on the lower of the declared value or assessed value, as stipulated by Presidential Decree No. 76. The petitioner also challenges the validity of the writ of execution and the subsequent garnishment of its funds. The Supreme Court, however, ruled that Presidential Decree No. 1533, which attempted to limit judicial discretion in determining just compensation, was unconstitutional, reaffirming that the determination of just compensation is a judicial function governed by Rule 67 of the Rules of Court.
Issue(s)
Whether the respondent judge committed a grave abuse of discretion and acted without jurisdiction in rendering the decision and issuing the writ of execution. Whether the determination of just compensation should be based on P.D. No. 76 or on the evidence presented and the discretion of the court.
Ruling
The petition is DISMISSED for lack of merit, without pronouncement as to costs.
Ratio Decidendi
On the issue of grave abuse of discretion and jurisdiction: The Court found that the respondent judge did not commit a grave abuse of discretion. The petitioner, through the City Mayor, submitted itself to the discretion of the court regarding the correct evaluation of the properties during the pre-trial conference. The private respondents also agreed to the proposed reasonable price. The City Assessor presented information on current market and appraisal values. Based on the evidence adduced and the parties' positions, the trial court rendered its judgment. The Court held that the findings of the trial court, supported by evidence, would not be disturbed on appeal unless a clear error or grave abuse of discretion was demonstrated, which was not the case here. On the determination of just compensation: The Court reiterated its ruling in Export Processing Zone Authority vs. Dulay that the determination of just compensation in eminent domain cases is a judicial function. Presidential Decrees that eliminate the court's discretion to appoint commissioners, such as P.D. No. 1533 (which relates to P.D. No. 76), are unconstitutional and void. Therefore, the ascertainment of just compensation is governed by Rule 67 of the Rules of Court, not by P.D. No. 76 and other related decrees. The trial court's determination of P30.00 per square meter was based on evidence presented during the pre-trial conference, including the location, condition, topography, improvements, and various comparable land transactions in the area. The court considered factors such as proximity to the industrial complex, accessibility, improvements, purpose of taking, and prevailing market trends. The trial court's findings were supported by the evidence and applicable law, thus the judgment was affirmed.
Main Doctrine
The determination of just compensation in eminent domain cases is a judicial function, and no statute, decree, or executive order can mandate that its own determination shall prevail over the court's findings. Presidential Decrees that eliminate the court's discretion to appoint commissioners are unconstitutional.