National Transmission Corporation v. Manalo
REITERATIONFacts
The Antecedents: Respondents spouses Manalo and the Pedrajas are owners of parcels of land in Tanauan City, Batangas. In 1998, the National Power Corporation (NAPOCOR), predecessor of petitioner National Transmission Corporation (TRANSCO), constructed a 500-kilovolt (KV) transmission line traversing respondents' properties without initiating expropriation proceedings. The affected areas were 2,376 square meters of Lot No. 1374-B-2 (spouses Manalo) and 10,534 square meters of Lot No. 1465-J (the Pedrajas). Procedural History: Respondents filed a Complaint for Inverse Condemnation against TRANSCO. They prayed, inter alia, for the determination of the fair market value of the lots pursuant to Republic Act No. 10752. Respondents filed a Motion to Require TRANSCO to Comply with Republic Act No. 10752, arguing that Section 6 of the law mandates a deposit of the BIR's current zonal valuation as provisional compensation. TRANSCO opposed, contending that R.A. 10752 applies only to new projects, not to existing transmission lines constructed before its enactment, and that provisional deposit should be based on the assessed value under Rule 67 of the Rules of Court. The Regional Trial Court (RTC) granted the motion, ordering TRANSCO to deposit PHP 47,818,500.00. Upon reconsideration, the RTC adjusted the amount to PHP 70,288,500.00 after finding a larger affected area for the Pedrajas. TRANSCO's Petition for Certiorari before the Court of Appeals (CA) was dismissed. The CA affirmed the RTC, holding that R.A. 10752 governs the determination of provisional compensation. The Petition: TRANSCO insists that Rule 67 of the Rules of Court should govern, as it was the law in effect at the time of construction in 1998, and R.A. 10752 cannot be given retroactive effect. TRANSCO also disputes the computation of the provisional deposit.
Issue(s)
Whether Republic Act No. 10752 is the applicable law in determining the provisional compensation for the subject lots, including considerations of retroactivity. Whether the computation of the provisional deposit should be based on Republic Act No. 10752 or Rule 67 of the Rules of Court, and the finality of factual findings regarding the amount of provisional compensation.
Ruling
The Petition is DENIED. The Decision dated December 12, 2022 and the Resolution dated April 4, 2023 of the Court of Appeals in CA-G.R. SP No. 171202 are AFFIRMED.
Ratio Decidendi
On the applicability and retroactivity of Republic Act No. 10752: The Court held that the Court of Appeals (CA) did not err in ruling that Section 6 of Republic Act No. 10752 governs the determination of the provisional deposit. Both Rule 67 of the Rules of Court and Republic Act No. 8974 (later repealed by Republic Act No. 10752) govern expropriation proceedings for national infrastructure projects. Rule 67, Section 2, allows entry upon deposit of the assessed value for taxation purposes. In contrast, Republic Act No. 8974, enacted in 2000, and subsequently Republic Act No. 10752, enacted in 2016, require a deposit of 100% of the property's value based on the current BIR zonal valuation before entry. The Court reiterated the ruling in Felisa Agricultural Corporation v. National Transmission Corporation, which held that if inverse condemnation proceedings are initiated after the effectivity of Republic Act No. 8974 (or its successor, Republic Act No. 10752), then said law shall govern both procedurally and substantially. In this case, the respondents initiated inverse condemnation proceedings on February 21, 2020, which is after the effectivity of Republic Act No. 10752. Therefore, the provisions of Republic Act No. 10752, specifically Section 6 thereof, apply to the determination of the provisional deposit. The Court clarified that while statutes are generally applied prospectively, this principle applies to rights arising from acts done under the former law. However, if a right is declared for the first time by a subsequent law, it takes effect from that time, even if it arises from acts subject to former laws, provided no acquired right is prejudiced. Republic Act No. 10752 prescribed a new standard for determining just compensation and provisional value in expropriation cases for national government infrastructure projects, a matter not specifically covered under Rule 67. The right to a provisional deposit equivalent to 100% of the zonal value was declared for the first time by Republic Act No. 8974. Since the inverse condemnation proceedings were initiated after the effectivity of Republic Act No. 10752, the law governs the determination of the provisional value. The Court distinguished this case from Republic v. Estate of Posadas III, where an expropriation action was initiated prior to the taking of the property. Here, no expropriation was commenced, and the inverse condemnation proceedings, where the right to provisional compensation was invoked, were filed when Republic Act No. 10752 was already in effect. On the computation of provisional compensation and the finality of factual findings: The Court held that the value of the provisional compensation is a question of fact, which cannot be raised in a petition for review on certiorari under Rule 45. Factual findings of the trial court, when affirmed by the CA, are binding on the Supreme Court. Therefore, the Court found no reason to deviate from the CA's findings regarding the amount of provisional compensation.
Main Doctrine
The provisions of Republic Act No. 10752, which mandates a provisional deposit equivalent to 100% of the BIR zonal valuation for national government infrastructure projects, shall govern inverse condemnation proceedings initiated after its effectivity, even if the property was taken prior to its enactment.