Bank of the Philippine Islands v. National Power Corporation
REITERATIONFacts
The Antecedents: The National Power Corporation (NAPOCOR) filed a complaint for eminent domain to expropriate a portion of petitioner Bank of the Philippine Islands' (BPI) property for the construction of a transmission line. NAPOCOR deposited P3,013.60 as the assessed value of the property and was granted a writ of possession. Procedural History: The trial court initially denied BPI's motion for a bill of particulars, then granted BPI's motion to dismiss, which was later reinstated upon NAPOCOR's motion for reconsideration. The trial court designated three commissioners to determine just compensation. The commissioners submitted a report assessing the property at P10,000.00 per square meter, totaling P753,400.00 for 75.34 square meters, and recommended additional severance damages. The trial court rendered judgment in favor of BPI, ordering NAPOCOR to pay P10,000.00 per square meter and P10,000.00 as commissioner's fee for each commissioner. The Petition: NAPOCOR appealed to the Court of Appeals, which reversed the trial court's decision, reducing just compensation to P3,000.00 per square meter and commissioner's fees to P3,000.00 each. BPI filed a motion for reconsideration, which was denied. Hence, BPI filed a petition for review on certiorari, assailing the Court of Appeals' decision for allegedly gravely abusing its discretion and seriously erring in fixing the just compensation.
Issue(s)
Whether the Court of Appeals gravely abused its discretion and seriously erred in fixing the just compensation for the subject property at P3,000.00 per square meter. Whether the findings of fact of the Court of Appeals are contrary to those of the trial court, warranting an exception to the general rule in petitions for review on certiorari.
Ruling
The petition for review on certiorari is DENIED. The Decision of the Court of Appeals in CA-G.R. CV No. 69402, which reversed the decision of the Regional Trial Court of Imus, Cavite, Branch 21 in Civil Case No. 1298-96, is AFFIRMED in toto.
Ratio Decidendi
On the issue of whether the Court of Appeals gravely abused its discretion and seriously erred in fixing the just compensation for the subject property at P3,000.00 per square meter: The Court found no reason to disturb the findings of fact by the Court of Appeals, as they were sufficiently supported by the evidence on record. The Court noted that the rate imposed by the Commissioners was unsubstantiated, as no official documents were presented to reflect the true market value of the lots in the surrounding area. The Commissioners' Report merely stated that the valuation was based on sales and listings of comparable property without providing supporting evidence. In contrast, the Court gave more weight to Resolution No. 08-95 promulgated by the Provincial Appraisal Committee of Cavite, which pegged the fair and reasonable value of lots in Dasmariñas along General Aguinaldo Highway at P3,000.00 per square meter. This valuation was made closer to the date of taking and was supported by the fact that over 70% of lot owners had accepted this price in compromise agreements. Furthermore, one of the commissioners, Mr. Lamberto C. Parra, was the Chairman Provincial Assessor and signatory of the said Resolution, lending credibility to the P3,000.00 per square meter valuation. On the issue of whether the findings of fact of the Court of Appeals are contrary to those of the trial court, warranting an exception to the general rule in petitions for review on certiorari: The Court reiterated that while the general rule in petitions for review on certiorari under Rule 45 is that only questions of law may be raised, exceptions exist, including when the findings of fact of the Court of Appeals are contrary to those of the trial court. The case at bar falls under this exception. The Court found that the Court of Appeals' decision, which reduced the just compensation, was based on a more thorough evaluation of the evidence presented, particularly the Resolution of the Provincial Appraisal Committee, which was not adequately substantiated by the Commissioners' report. The appellate court's decision was therefore not a result of grave abuse of discretion but a proper exercise of its review powers when faced with conflicting factual findings between itself and the trial court, especially when the trial court's findings lacked sufficient evidentiary basis.
Main Doctrine
The Court of Appeals may overturn the findings of the trial court and commissioners on just compensation if the latter's valuation is unsubstantiated by evidence, especially when a more reliable valuation from a provincial appraisal committee exists and has been accepted by a significant majority of property owners in the area.