Republic v. Goloyuco
REITERATIONFacts
The Antecedents The Republic of the Philippines, through the Department of Public Works and Highways (DPWH), initiated an expropriation proceeding to acquire a 50-square meter parcel of land owned by Spouses Pedro and Zenaida Goloyuco in Valenzuela City. The property was intended for the construction of the C-5 Northern Link Road Project. The Republic deposited P137,500.00 as provisional compensation, and a writ of possession was issued. Subsequently, commissioners were appointed to determine the just compensation, with recommendations ranging from P10,000.00 to P12,250.00 per square meter. Procedural History The Regional Trial Court (RTC) of Valenzuela City, Branch 172, fixed the just compensation at P8,300.00 per square meter, totaling P415,000.00, and ordered the Republic to pay the unpaid balance with interest. The Republic appealed to the Court of Appeals (CA), which affirmed the RTC's decision with modification regarding the period and rate of interest. The CA ruled that 12% interest should apply from the date of taking until June 30, 2013, and 6% thereafter until full payment. The Republic's motion for reconsideration was denied by the CA. The Petition The Republic filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, arguing that the CA erred in upholding the trial court's determination of just compensation. The petitioner contended that the appraisal should be based on the BIR zonal valuation of P2,750.00 per square meter, asserting that this reflects the fair market value and prevents unjust enrichment. The respondents, Spouses Goloyuco, countered that the fair market value should consider prevailing selling prices of similar properties in the vicinity, which are significantly higher than the zonal valuation.
Issue(s)
Whether the Court of Appeals erred in upholding the trial court's decision fixing just compensation for the subject property at ₱8,300.00 per square meter. Whether the zonal valuation should be the sole basis for determining just compensation.
Ruling
The petition is denied for lack of merit. The assailed Decision and Resolution of the Court of Appeals are affirmed, fixing the just compensation at ₱8,300.00 per square meter, or a total of ₱415,000.00. The ruling is modified regarding the reckoning period of the 12% per annum legal interest and the imposition of additional 6% per annum interest on the total amount of just compensation.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in upholding the trial court's decision fixing just compensation at ₱8,300.00 per square meter: The Supreme Court held that factual findings of the lower courts, particularly on the value of expropriated property, are generally not disturbed in a petition for review on certiorari under Rule 45, as these are questions of fact. The petitioner failed to allege or prove any exceptional circumstances warranting a deviation from this rule. The Court affirmed that the CA, in upholding the RTC's valuation, considered various factors beyond mere zonal valuation, including the Commissioners' reports based on previously expropriated properties, the distance of those properties, and the subject property's shape, nature, use, and location, in compliance with Section 5 of R.A. No. 8974. The Court reiterated that zonal valuation is merely one of the indices for fair market value and cannot be the sole basis for just compensation. On the issue of whether the zonal valuation should be the sole basis for determining just compensation: The Court reiterated the established rule that zonal valuation, while an index of fair market value, is not the sole determinant of just compensation in expropriation cases. Section 5 of R.A. No. 8974 provides several standards for assessment, including 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 relevant facts enabling property owners to acquire similarly-situated lands. The Court emphasized that just compensation is the full and fair equivalent of the property taken, measured by the owner's loss, not the taker's gain. The provisional value paid for the writ of possession, often based on zonal valuation, is distinct from the final determination of just compensation, which must reflect the prevailing fair market value.
Main Doctrine
The zonal valuation, while an index of fair market value, cannot be the sole basis for just compensation in expropriation cases. The determination of just compensation must consider various factors enumerated under Section 5 of R.A. No. 8974, including the current selling price of similar lands, location, shape, and use of the property, to arrive at the full and fair equivalent of the property taken.