Republic v. Decena
REITERATIONFacts
The Antecedents: The Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH), initiated five (5) separate expropriation complaints against respondents' properties in Quezon City for the Circumferential Road 5 (C5 Road) Extension Road Widening Project. Attempts at negotiated sale failed. The DPWH deposited 100% of the current zonal valuation with the Land Bank of the Philippines and obtained a Writ of Possession. Procedural History: The Regional Trial Court (RTC) issued an Order of Condemnation and created a Board of Commissioners (BOC) to determine just compensation. The BOC recommended P17,893.33 per square meter. Respondents submitted a valuation of P30,000.00 per square meter from the Philippine Appraisal Company, Inc. (PACI). The RTC fixed just compensation at P25,000.00 per square meter, finding the BOC and PACI valuations insufficient on their own. The Court of Appeals (CA) affirmed the RTC's decision in toto. The Petition: The Republic, through the OSG, filed a petition for review on certiorari, assailing the CA's affirmation of the RTC's determination of just compensation, arguing that the RTC erred in not according greater weight to the BOC's recommendation and that the P25,000.00 valuation was not fully justified by the statutory standards.
Issue(s)
Whether the Court of Appeals committed reversible error in affirming the RTC's determination of just compensation for the expropriated property at P25,000.00 per square meter. Whether the RTC and CA fully considered the standards laid down in Section 5 of R.A. 8974 in determining just compensation. Whether interest is due on the unpaid portion of just compensation and from what date it should run.
Ruling
The petition is denied. The Court affirmed the Court of Appeals' Decision dated February 28, 2014, and Resolution dated May 28, 2014, which upheld the Regional Trial Court's determination of just compensation at P25,000.00 per square meter. The Court ordered the RTC to compute the unpaid portions of just compensation and the corresponding interest thereon, to be paid to the respondents.
Ratio Decidendi
On the issue of whether the CA committed reversible error in affirming the RTC's determination of just compensation: The Court held that issues pertaining to the value of expropriated property are questions of fact, which are generally beyond the scope of a Rule 45 petition. The petitioner failed to allege or prove any exceptional circumstances that would warrant a deviation from this rule. Therefore, the denial of the petition on this ground alone is warranted. On whether the RTC and CA fully considered the standards laid down in Section 5 of R.A. 8974: The Court reiterated that the determination of just compensation is a judicial function, and the standards provided in Section 5 of R.A. 8974 are merely guides that courts may consider. The RTC, in fixing the compensation at P25,000.00 per square meter, considered the BOC's valuation (P17,893.33) and the PACI's valuation (P30,000.00) as guideposts. The RTC found both valuations insufficient on their own, and exercised its discretion to arrive at a fair market value. The CA correctly affirmed this exercise of discretion, finding that the RTC considered all submitted data and evidence judiciously. The Court found no abuse, arbitrariness, or serious error in the lower courts' determination. On the issue of interest due on the unpaid portion of just compensation: The Court held that while the initial deposit made by the government complied with R.A. 8974, it does not constitute full just compensation. Just compensation requires prompt payment in full. When the government takes possession of the property before full payment of the determined just compensation, interest on the unpaid portion runs as a matter of law. This interest is necessary to place the owner in as good a position as they were before the taking. The Court clarified that interest accrues from the date of taking, which, in this case, is the date of the filing of the complaint, until full payment is made. The RTC was ordered to compute the unpaid portion and the corresponding legal interest from the respective dates of filing of the complaints.
Main Doctrine
The determination of just compensation in expropriation cases is a judicial function that requires courts to consider statutory standards, but ultimately rests on the court's sound discretion. Absent a showing of abuse, arbitrariness, or serious error, the exercise of this discretion will not be interfered with. Furthermore, interest on the unpaid portion of just compensation runs as a matter of law from the date of taking to ensure the owner is placed in as good a position as before the taking.