National Power Corp. v. Diato-Bernal
REITERATIONFacts
The Antecedents: Petitioner National Power Corporation (NAPOCOR) filed an expropriation suit against respondent Teresita Diato-Bernal to acquire an easement of right of way over her 946 sq m property for the "Dasmariñas-Zapote 230 KV Transmission Line Project." NAPOCOR alleged failure to reach an agreement on the price. Procedural History: The parties executed a partial compromise agreement regarding the location and size of the pole site, but agreed to proceed to trial on the issue of just compensation. The Regional Trial Court (RTC), based on the report of court-appointed commissioners, fixed just compensation at ₱10,000.00 per square meter. NAPOCOR opposed this, arguing the report was unsubstantiated and proposed ₱3,500.00 per square meter based on a Provincial Appraisal Committee (PAC) resolution. The Court of Appeals (CA) affirmed the RTC's decision. The Petition: NAPOCOR sought review, arguing the CA erred in affirming the RTC's reliance on the unsubstantiated commissioners' report and questioning the significant increase in property valuation.
Issue(s)
Whether the Court of Appeals erred in affirming the Regional Trial Court's reliance on the unsubstantiated findings of the commissioners' report in determining just compensation. Whether the determination of just compensation was made as of the time of the taking of the property.
Ruling
The petition is meritorious. The Court set aside the orders of the RTC and the CA and remanded the case for the proper determination of just compensation.
Ratio Decidendi
On the issue of reliance on the commissioners' report: The Court found that the CA and the RTC erred in relying on the unsubstantiated and insufficient findings contained in the commissioners' report. The report's conclusions regarding market values were speculative and unsupported by corroborative documents such as sworn declarations, tax declarations, or zonal valuations. The report also failed to elaborate on how community centers and convenience facilities enhanced the property's value, and the market sales data alluded to were not appended. Citing Rep. of the Phil. v. Santos, the Court reiterated that a commissioners' report not based on documentary evidence is hearsay and should be disregarded. The trial court's adoption of these flawed findings without requiring submission of the alleged supporting data was improper. The Court emphasized that just compensation requires reliable and actual data as bases. On the issue of the time of taking for just compensation: The Court noted that the RTC overlooked the fact that the recommended just compensation was gauged as of September 10, 1999, more than two years after the complaint was filed on January 8, 1997. It is settled that just compensation is to be ascertained as of the time of the taking, which usually coincides with the commencement of the expropriation proceedings. Where the institution of the action precedes entry into the property, the just compensation is to be ascertained as of the time of the filing of the complaint. Therefore, the recommended just compensation in the commissioners' report was unacceptable as it was not determined as of the proper valuation date.
Main Doctrine
The determination of just compensation in expropriation cases is a judicial function. A commissioners' report not based on documentary evidence is hearsay and should be disregarded. Just compensation must be ascertained as of the time of the taking, which usually coincides with the commencement of the expropriation proceedings.