Tiongson v. National Housing Authority
REITERATIONFacts
The Antecedents: The National Housing Authority (NHA) took possession of properties belonging to petitioners Patricia L. Tiongson, et al. in 1978, pursuant to Presidential Decree (P.D.) Nos. 1669 and 1670. Subsequently, this Court declared P.D. Nos. 1669 and 1670 unconstitutional in G.R. Nos. L-55166 and L-55167, finding them violative of the right to due process. The decision became final and executory. Procedural History: On September 14, 1987, the NHA filed a new complaint for expropriation before the Regional Trial Court (RTC) of Manila (Civil Case No. 87-42018) concerning part of the properties previously involved. The RTC, by Order dated April 29, 1997, ruled that the determination of just compensation should be reckoned from the date of filing of the complaint (September 14, 1987), brushing aside a previous order. The NHA moved for reconsideration, arguing that compensation should be based on the 1978 taking. The RTC denied the motion. The NHA then filed a petition for certiorari before the Court of Appeals (CA). The CA reversed the RTC's orders, holding that just compensation should be based on the actual taking in 1978. The Petition: Petitioners seek a review of the CA's decision, arguing that since the initial taking was based on an unconstitutional decree, it is unlawful to reckon just compensation from that date. They maintain that the RTC's ruling to reckon from the filing of the new complaint on September 14, 1987, is correct.
Issue(s)
Whether the just compensation for the expropriated properties should be reckoned from the date of the initial taking in 1978 or from the date of the filing of the subsequent expropriation complaint on September 14, 1987. Whether the Court of Appeals erred in reversing the Regional Trial Court's order and in relying on a previous order that was not properly considered in light of the NHA's judicial admissions.
Ruling
The Supreme Court reversed and set aside the Court of Appeals' decision and reinstated the Regional Trial Court's order dated April 29, 1997. The Court ruled that the just compensation should be determined as of the date of the filing of the complaint on September 14, 1987.
Ratio Decidendi
On the reckoning date for just compensation: The Court held that the just compensation for the expropriated properties must be determined as of the date of the filing of the complaint, which was September 14, 1987. This is in accordance with Rule 67, Section 4 of the Rules of Court, which states that just compensation shall be determined as of the date of the taking of the property or the filing of the complaint, whichever came first. In this case, the initial taking in 1978 was based on P.D. Nos. 1669 and 1670, which were later declared unconstitutional. Therefore, the initial taking was unlawful and cannot serve as the reckoning point for just compensation. The subsequent filing of a valid expropriation complaint on September 14, 1987, thus becomes the operative date. On the Court of Appeals' reliance on previous orders and judicial admissions: The Court found that the Court of Appeals erred in relying solely on an earlier order of the trial court which, by agreement of the parties, fixed a provisional value and authorized retention of possession based on the 1978 taking. This reliance was made despite the fact that the NHA's own Petition for Expropriation filed before the RTC contained judicial admissions that it possessed the properties until P.D. No. 1669 was declared unconstitutional. These admissions, which acknowledged the unconstitutionality of the basis for the initial taking, were crucial and should have been considered by the appellate court. The Court noted that the appellate court's decision glaringly shows that these judicial admissions were not considered, leading to an erroneous conclusion.
Main Doctrine
In expropriation cases, where the initial taking of property was based on an unconstitutional decree, the just compensation should be reckoned from the date of the filing of the subsequent, valid expropriation complaint, not from the date of the initial unlawful taking.