Republic v. Legaspi
REITERATIONFacts
The Antecedents: The Republic of the Philippines (petitioner) filed a complaint for expropriation against respondents, who were the registered owners of lots in Calamba City, Laguna. These lots, with a total area of 13,002 square meters, were sought to be expropriated for the South Luzon Tollway Extension Project. Respondent Rural Bank of Calamba (Laguna), Inc. was impleaded as the lot of Spouses Legaspi and Esquito was mortgaged to it. Procedural History: Petitioner filed an Urgent Ex Parte Motion for Issuance of Writ of Possession, having deposited P3,120,480, representing 100% of the zonal value (P240/sq.m.). Respondents moved to correct the initial deposit, arguing the BIR zonal valuation should be P2,500/sq.m. as the lots were commercial, and also moved for payment of improvements. The trial court granted the writ of possession, ordered petitioner to deposit the difference (P29,384,020) based on the P2,500/sq.m. valuation, and directed payment for improvements. A writ of possession was issued. The Board of Commissioners was constituted and, after ocular inspections and hearings, submitted a report recommending just compensation ranging from P2,500 to P4,500 per square meter. The trial court initially fixed just compensation at P3,500/sq.m. However, upon petitioner's motion for reconsideration, the trial court lowered it to P240/sq.m., deeming the potential commercial use speculative. Subsequently, the trial court set aside its resolution and reinstated its original decision of P3,500/sq.m. The Court of Appeals affirmed the trial court's decision, holding that just compensation is based on market value, not solely on zonal value, and considering various factors including the Commissioners' Report and the Mayor's certification. The Petition: Petitioner seeks review of the Court of Appeals' decision, arguing that the P3,500/sq.m. valuation is excessive and not supported by evidence, and that just compensation should be P240/sq.m. based on the BIR zonal value and agricultural classification of the lots.
Issue(s)
Whether the Court of Appeals erred in upholding the trial court's decision and order, fixing just compensation for the subject lots at P3,500 per square meter. Whether the BIR zonal value of P240 per square meter should be the sole basis for just compensation.
Ruling
The petition is denied. The Decision dated 18 August 2015 and the Resolution dated 24 November 2015 of the Court of Appeals in CA-G.R. CV No. 103375 are affirmed.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in upholding the trial court's decision and order, fixing just compensation for the subject lots at P3,500 per square meter: The Supreme Court found the petition without merit. It reiterated that in a petition for review on certiorari under Rule 45, only questions of law may be raised, and factual issues concerning property valuation are generally beyond its scope. The Court noted that the factual findings of the trial court, when affirmed by the Court of Appeals, are binding and conclusive, unless essential facts were overlooked or misinterpreted. In this case, the Court found no reason to deviate from the findings of the lower courts. The Court of Appeals correctly affirmed the trial court's valuation by considering various factors beyond the BIR zonal value, including the Commissioners' Report, the classification and valuation certified by the Mayor, prices paid to other landowners, and the potential use of the property. The Court emphasized that just compensation is the full and fair equivalent of the property taken, not merely the taker's gain but the owner's loss. On the issue of whether the BIR zonal value of P240 per square meter should be the sole basis for just compensation: The Supreme Court ruled that the zonal valuation cannot be the sole basis for determining just compensation. This is consistent with jurisprudence and Section 5 of Republic Act No. 8974, which enumerates several standards for assessing the value of land subject to expropriation. These standards include the classification and use of the property, developmental costs, declared values, current selling prices of similar lands, disturbance compensation, size, shape, location, tax declaration, zonal valuation, and other factors enabling the owner to rehabilitate themselves. The Court found petitioner's insistence on the P240 per square meter zonal value, which was significantly lower than other valuations and market indicators, to be outrageous and unjustified. The Court of Appeals' affirmation of P3,500 per square meter as just compensation was deemed fair and sensible, representing a reasonable compromise between the parties' proposals and supported by the evidence presented.
Main Doctrine
The zonal valuation, being merely one of the indices of the fair market value of real estate, cannot be the sole basis for the determination of just compensation of properties under expropriation. Other factors enumerated under Section 5 of RA 8974 must be considered.