National Power Corporation v. Cruz
REITERATIONFacts
The Antecedents: The National Power Corporation (Napocor) filed an expropriation proceeding against various respondents who are owners of lots in Del Monte Park Subdivision, San Jose Del Monte, Bulacan. The purpose was to determine just compensation after negotiations for purchase failed. The Regional Trial Court (RTC) directed the Bulacan Provincial Appraisal Committee (PAC) to submit an appraisal report. Napocor was allowed to take possession upon depositing the assessed value. Procedural History: The PAC submitted a report pegging just compensation at ₱2,200.00 per square meter. The RTC, considering economic crises and peso devaluation, fixed just compensation at ₱3,000.00 per square meter. Napocor appealed to the Court of Appeals (CA), assailing the PAC's appointment and the basis for the compensation amount. The Petition: The CA affirmed the RTC's order with modification, upholding the ₱2,200.00 per square meter but imposing 12% legal interest instead of the additional ₱800.00. Napocor filed a petition for review on certiorari with the Supreme Court, arguing that the PAC's appointment was contrary to Rule 67, that the compensation amount lacked basis, and that the CA erred in disregarding a compromise agreement fixing compensation at ₱1,900.00 per square meter.
Issue(s)
Whether the appointment of the Provincial Appraisal Committee (PAC) as commissioners substantially complied with Section 5, Rule 67 of the Rules of Court. Whether Napocor was denied due process in the determination of just compensation. Whether the Court of Appeals erred in disregarding the compromise agreement entered into by Napocor and some respondents. Whether Atty. Pedro Principe is entitled to attorney's fees and has the authority to represent certain respondents.
Ruling
The Supreme Court denied the petition, affirming the decision of the Court of Appeals. The issues concerning Atty. Pedro Principe's representation and entitlement to attorney's fees were remanded to the Regional Trial Court for resolution.
Ratio Decidendi
On the appointment of the PAC as commissioners: The Court held that the appointment of the PAC substantially complied with Section 5, Rule 67 of the Rules of Court. Although the rule specifies appointing "not more than three (3) competent and disinterested persons," the PAC, composed of the Provincial Assessor, Provincial Engineer, and Provincial Treasurer, fulfilled this requirement. Their positions ensured competence and disinterest, and their task was to ascertain and report just compensation, aligning with the commissioners' duty. The Court emphasized that Napocor's failure to timely object to the PAC's appointment before the RTC constituted a waiver of such objections, as these were only raised belatedly before the CA. The Court reiterated that objections to the appointment of commissioners must be filed within ten (10) days from service of the order of appointment, as stipulated in the Rules of Court. On the denial of due process in the determination of just compensation: The Court found no denial of due process. It presumed regularity in the performance of official functions by the PAC members, who are considered officers of the court. The Court found it unlikely that Napocor was unaware of the proceedings, given its vested interest. Furthermore, Napocor's claim that the compensation amount lacked basis was untenable. The Court noted that Napocor itself acknowledged an increase in property values by modifying its settlement offer. Crucially, the Land Bank of the Philippines (LBP) Appraisal Report, commissioned by Napocor, also pegged the fair market value at ₱2,200.00 per square meter, corroborating the PAC's findings. Similar to the objections on appointment, Napocor's failure to file timely objections to the commissioners' report within the ten-day period provided by Section 7, Rule 67 of the Rules of Court, and raising them only before the CA, resulted in a waiver of these objections. On the compromise agreement: The Court found Napocor's pattern of procrastination evident in its handling of the compromise agreement. Despite numerous extensions granted by the CA to submit the agreement, Napocor consistently failed to do so. The Court noted that the CA was compelled to resolve the appeal based on available records due to this inaction. The Court also clarified that the execution of a compromise agreement does not automatically enjoin an appellate court from resolving an appeal; it requires the court's approval to take effect. Napocor's failure to furnish the CA with a copy of the agreement precluded it from assailing the CA's authority to proceed with the resolution of the appeal. On the representation of Atty. Principe: The Court acknowledged the respondents' misgivings regarding Atty. Principe's claims. While a previous ruling in Malonso v. Principe found reasonable grounds for Atty. Principe's authority to represent SANDAMA and its members, the Court found insufficient documentation in the present case to conclusively determine his authority to represent these specific respondents or his entitlement to attorney's fees. Therefore, the Court deemed it prudent to remand the matter to the RTC for a determination of Atty. Principe's authority and entitlement to fees, considering the ruling in Malonso.
Main Doctrine
The appointment of a committee composed of competent and disinterested government officials (such as the Provincial Assessor, Provincial Engineer, and Provincial Treasurer) substantially complies with the requirements of Section 5, Rule 67 of the Rules of Court for the appointment of commissioners in expropriation proceedings. Failure to timely object to the appointment of commissioners or to their report constitutes a waiver of such objections.