Republic v. Cancio
REITERATIONFacts
The Antecedents: The Philippine Economic Zone Authority (PEZA), a government-owned and controlled corporation with the power of eminent domain, sought to expropriate parcels of land in Lapu-Lapu City for the Mactan Export Processing Zone. Among these was a 47,540 sq. m. lot owned by respondents Spouses Agustin and Imelda Cancio. PEZA had previously leased the lot to an investor, Maitland Smith Inc. PEZA offered to purchase the lot for ₱52,294,000, or ₱1,100 per sq. m., and warned of expropriation proceedings if the offer was not accepted. Procedural History: Instead of accepting the offer, the respondents filed an unlawful detainer case against the lessee. PEZA then commenced expropriation proceedings, seeking a writ of possession upon depositing 10% of its offered amount (₱5,229,400) with the Land Bank of the Philippines, citing Administrative Order (A.O.) No. 50. Respondents moved to require PEZA to comply with Republic Act (RA) No. 8974, which mandates payment of 100% of the current zonal valuation for the issuance of a writ of possession. The Regional Trial Court (RTC) initially granted respondents' motion but later reconsidered, agreeing with PEZA that RA 8974 was inapplicable. The RTC reversed itself again, reinstating its initial order. PEZA filed a petition for certiorari with the Court of Appeals (CA), which affirmed the RTC's ruling. The Petition: PEZA filed a petition for review on certiorari with the Supreme Court, arguing that RA 8974 was inapplicable and that A.O. No. 50 governed its offer to purchase.
Issue(s)
Whether Republic Act No. 8974 is applicable to the case for purposes of the issuance of a writ of possession. Whether the trial court erred in requiring petitioner to comply with RA 8974 for the issuance of a writ of possession, confusing the provisional value with the final just compensation, and whether the trial court's ministerial duty to issue the writ was correctly understood.
Ruling
The petition is denied. The Court of Appeals did not err in affirming the Regional Trial Court's ruling that Republic Act No. 8974 governs the case for purposes of the issuance of a writ of possession.
Ratio Decidendi
On the applicability of RA 8974 for the issuance of a writ of possession: The Supreme Court held that Republic Act No. 8974 clearly governs this case because the expropriation complaint was filed after RA 8974 was approved, and the economic zone project is a national government project falling within the scope of RA 8974. The requirement of paying 100% of the current zonal valuation under Section 4(a) of RA 8974 is a prerequisite for the issuance of a writ of possession, distinct from the final determination of just compensation. On the trial court's alleged error: The Court clarified that the trial court has a ministerial duty to issue the writ upon compliance with the law's requirements, without needing a hearing for this preliminary determination. The provisional value required for the writ is based on the current zonal valuation, while just compensation is based on the fair market value at the time of taking. The petitioner's confusion between provisional value and final just compensation is addressed by distinguishing the preliminary determination of value for a writ of possession from the final determination of just compensation, as per Capitol Steel Corporation v. PHIVIDEC Industrial Authority. The provisional value is not a final determination and may be a factor in determining just compensation, but it is not necessarily equivalent to the fair market value. The law mandates the trial court to determine just compensation within sixty days from the filing of the expropriation case, and the Court directed compliance within sixty days from the finality of its decision.
Main Doctrine
Republic Act No. 8974, which requires the payment of 100% of the current zonal valuation for the issuance of a writ of possession in expropriation cases, governs over Administrative Order No. 50, which allows for a deposit of 10% of the offered amount. The provisional value for a writ of possession is distinct from the final determination of just compensation.