Republic v. Frias
REITERATIONFacts
The Antecedents: The Republic of the Philippines, through the Department of Public Works and Highways (DPWH), instituted an expropriation case for a 468 sq. m. parcel of land owned by Edesio T. Frias, Sr. (Frias) for the Cotabato-Agusan River Basin Development Project. The Republic deposited P81,900.00 as the assessed value and obtained a Writ of Possession. The parties initially agreed to enter into a compromise agreement regarding just compensation, but negotiations failed. Procedural History: Due to the prolonged negotiations and delays, the trial court, upon motion by Frias' counsel and without objection from the Republic's counsel, dispensed with the appointment of a Board of Commissioners (BOC) and required the parties to submit position papers. The Republic presented a Tax Declaration (P90.00/sq. m.) and BIR Zonal Valuation (P263.14/sq. m.), asserting compensation between these values. Frias claimed P980.00/sq. m. based on developments and adjacent property valuations, submitting a Deed of Absolute Sale for a similarly situated land. The Regional Trial Court (RTC) set just compensation at P737.83 per sq. m., based on the Deed of Absolute Sale, awarding Frias P345,304.44 plus legal interest. The RTC denied the Republic's motion for reconsideration. The Court of Appeals (CA) affirmed the RTC's decision, finding no denial of due process and upholding the RTC's exercise of discretion based on competent evidence. The CA denied the Republic's motion for reconsideration. The Petition: The Republic filed a Petition for Review on Certiorari, arguing that its right to due process was violated by the RTC dispensing with the BOC and not being given an opportunity to scrutinize Frias' documentary submissions. It also questioned the amount of just compensation, asserting the Deed of Absolute Sale was hearsay evidence.
Issue(s)
Whether the Court of Appeals committed an error in ruling that petitioner's right to due process was not violated. Whether the Court of Appeals committed an error in affirming the amount of just compensation determined by the trial court.
Ruling
The petition is DENIED for utter lack of merit. The Court of Appeals' Decision dated August 31, 2018 and its Resolution dated December 18, 2018 in C.A. G.R. CV No. 04642-MIN are AFFIRMED. Respondent Edesio T. Frias, Sr. is entitled to P345,304.44, plus legal interest of twelve percent (12%) from December 14, 2005 until June 30, 2013, and six percent (6%) from July 1, 2013 until fully paid as just compensation.
Ratio Decidendi
On the issue of due process: The Court held that the Republic's right to due process was not violated. The essence of procedural due process lies in notice and a real opportunity to be heard, which can be through pleadings. The Republic was given every reasonable opportunity to present its case, including filing a position paper and having ample time (nine months) to comment on Frias' submitted documents before the RTC rendered its decision. Furthermore, the Republic's counsel did not object to dispensing with the Board of Commissioners (BOC) during the hearing on August 29, 2014, after years of postponements at the Republic's behest for negotiations. The Court noted that any alleged defect in procedural due process was cured by the Republic's subsequent filing of a motion for reconsideration and an appeal before the CA, as well as its opportunity to file the present petition for review. The Court reiterated that a party cannot claim denial of due process when afforded opportunities to be heard through pleadings and appeals. On the issue of just compensation: The Court affirmed the CA's upholding of the RTC's determination of just compensation. The Court reiterated that the determination of just compensation is a judicial function requiring the reception of reliable and actual data and circumspect evaluation thereof. While the Republic questioned the Deed of Absolute Sale as hearsay, the RTC considered it along with other factors, and importantly, did not solely rely on it. The RTC correctly disregarded the Republic's assertion that compensation should be strictly between the tax declaration and zonal valuation, as zonal valuations are not the sole basis for just compensation. The RTC also noted that Frias failed to submit sufficient evidence for his claimed P980.00/sq. m. valuation. The Court emphasized that it is not a trier of facts, and factual findings of the RTC, affirmed by the CA, are generally binding. The Republic failed to demonstrate that the RTC acted arbitrarily or capriciously, nor did it argue that the determined compensation was grossly exorbitant or unjustified. Therefore, the amount of just compensation was deemed properly arrived at based on established rules, correct legal principles, and competent evidence.
Main Doctrine
The Republic's right to due process was not violated in an expropriation case when it was afforded ample opportunity to be heard through pleadings and was given a reasonable period to comment on submitted documents, and any procedural defect was cured by its subsequent motion for reconsideration and appeal. The determination of just compensation is a judicial function that requires circumspect evaluation of reliable and actual data, and factual findings of the trial court affirmed by the Court of Appeals are binding on the Supreme Court.