Republic v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: The Department of Public Works and Highways (DPWH) expropriated three parcels of land owned by Emilia H. Miraflores and Gregorio M. Tirol for the construction and widening of the Iloilo Jaro Road. The DPWH deposited P177,237.92 representing the aggregate assessed value of the properties, computed in accordance with Presidential Decree No. 76. Procedural History: Emilia Miraflores and Gregorio M. Tirol filed separate Motions for Payment of Just Compensation, asserting that the assessed value should be based on the market value declared in their Sworn Statements filed with the City Assessor in accordance with Presidential Decree No. 464, or the market value declared by the City Assessor in Tax Declarations. The trial court ruled in favor of P.D. 464, stating that the value of residential land had increased since the sworn statements required by P.D. 76 until June 1977 when sworn statements were required under P.D. 464. The Intermediate Appellate Court affirmed the trial court's decision. The Petition: The Republic of the Philippines, represented by the DPWH, sought to review and annul the decision of the respondent court, asserting that the higher valuations made pursuant to P.D. 464 could not apply because assessments under P.D. 464 Sections 21 and 24 were to take effect in 1979, while the expropriation case was filed in 1977. Petitioner argued that the fair market value should be fixed as of the date the complaint was filed or based on P.D. 76.
Issue(s)
Whether Presidential Decree No. 464 or Presidential Decree No. 76 should apply in the payment of compensation in the expropriation case. Whether the higher valuations made by the City Assessor pursuant to P.D. 464 can be applied when the expropriation case was filed prior to the effectivity of the said assessments.
Ruling
The petition is denied, and the assailed decision is affirmed.
Ratio Decidendi
On the applicability of P.D. 464 versus P.D. 76: The Court held that P.D. 464, which took effect on June 1, 1974, should apply in the expropriation case filed in 1977. This decree mandated the upgrading of assessment services and required landowners to file sworn statements declaring the true current and fair market value of their properties. The valuation made in 1972 under P.D. 76 was rendered obsolete by the passage of P.D. 464, which aimed to correct inaccurate assessments and ensure equitable distribution of the realty tax burden. The Court emphasized that P.D. 464 required appraisals as of January 1977, making the valuations in the tax declarations relevant to the expropriation proceedings initiated in 1977. On the effectivity of P.D. 464 assessments: The Court found the petitioner's contention that the P.D. 464 assessments were not yet effective in 1977 to be meritless. While the taxes under the new declarations would be effective in 1979, the valuation of the market value therein was indeed for the year 1977, precisely for comparison with the market value declared by landowners as of January 1977, as mandated by P.D. 464. The Court noted that P.D. 464 is remedial in character. Furthermore, Section 92 of P.D. 464 mandates that in determining just compensation, the basis shall be the market value declared by the owner or administrator or such market value as determined by the assessor, whichever is lower. In this case, the landowners were satisfied with the assessor's appraisal, even if lower than their own declared values, to expedite receiving their just compensation.
Main Doctrine
In expropriation cases, the basis for just compensation shall be the market value declared by the owner or administrator or such market value as determined by the assessor, whichever is lower, pursuant to Section 92 of P.D. 464, provided that the landowners are satisfied with the appraisal and seek to receive just compensation early.