Marabeles v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the determination of just compensation for private property expropriated by the Republic of the Philippines, represented by the Leyte Sab-a Basin Development Authority, for the establishment of an industrial estate in Isabel, Leyte. This expropriation was initiated pursuant to Letter of Instructions No. 962. 2. Procedural History: The Leyte Sab-a Basin Development Authority filed an eminent domain action. The Regional Trial Court of Ormoc City issued an order of condemnation and appointed commissioners to determine just compensation. While most defendants accepted the tendered amounts, Raymundo Marabeles and Paciano Delalamon disputed the commissioners' report and presented countervailing evidence. The Trial Court rendered a decision awarding P45,000 to Marabeles and P19,000 to Delalamon. Marabeles and Delalamon appealed to the Court of Appeals, which affirmed the Trial Court's decision but modified it by reducing the compensation to P6,470 for Marabeles and P10,310 for Delalamon, applying the provisions of P.D. No. 464. 3. The Petition: Petitioners Marabeles and Delalamon seek a review on certiorari of the Court of Appeals' judgment. They argue that the Court of Appeals erred in applying P.D. No. 464, which this Court had previously declared unconstitutional and void in Export Processing Zone Authority v. Dulay and subsequent cases, insofar as it prescribed an unconstitutional mode for ascertaining just compensation. The petition contends that the Trial Court correctly relied on Rule 67 of the Rules of Court for determining just compensation and that the factual findings of the commissioners, adopted by the Trial Court, should be upheld.
Issue(s)
Whether the Court of Appeals erred in applying P.D. No. 464 in determining just compensation in an expropriation proceeding. Whether the Court of Appeals erred in reducing the just compensation awarded by the Regional Trial Court.
Ruling
The Supreme Court reversed the decision of the Court of Appeals and reinstated the decision of the Regional Trial Court. It held that P.D. No. 464, as amended, was unconstitutional and void insofar as it prescribed a mode for ascertaining just compensation that encroached upon judicial prerogatives. The Court affirmed that the determination of just compensation is a judicial function.
Ratio Decidendi
On the issue of applying P.D. No. 464: The Court reiterated its ruling in Export Processing Zone Authority v. Dulay, which declared P.D. No. 464, as amended, unconstitutional and void. The decree's provision that just compensation shall not exceed the lower of the market value declared by the owner or assessor was an impermissible encroachment on judicial prerogatives. The Court emphasized that the determination of 'just compensation' is a judicial function, and neither the executive nor the legislature can mandate that its own determination shall prevail over the court's findings. The courts cannot be precluded from looking into the 'just-ness' of the decreed compensation. Applying this unconstitutional decree, as the Court of Appeals did, was therefore erroneous. On the issue of reducing just compensation: Since the Court of Appeals erred in applying an unconstitutional law (P.D. No. 464), its reduction of the compensation awarded by the RTC was also set aside. The Court found that the RTC was correct in relying on Rule 67 of the Rules of Court and ascertaining just compensation with the aid of commissioners. The factual findings of these commissioners, which were approved and adopted by the RTC, were not sufficiently justified for modification by the Court of Appeals. The Supreme Court found no circumstance warranting a review of these factual findings, adhering to the general rule that issues of fact are not proper in appeals on certiorari.
Main Doctrine
The determination of 'just compensation' in eminent domain cases is a judicial function. No statute, decree, or executive order can mandate that its own determination shall prevail over the court's findings, nor can courts be precluded from looking into the 'just-ness' of the decreed compensation. Presidential Decree No. 464, as amended, insofar as it prescribed a mode for ascertaining just compensation that limited the court's determination to the lower of the owner's or assessor's declared market value, was declared unconstitutional and void for encroaching on judicial prerogatives.