Tayabas v. Perez
REITERATIONFacts
The Antecedents: The Province of Tayabas initiated an action for the expropriation of land in Lucena, Tayabas. Appraising commissioners were appointed, who recommended specific values for two lots (X-1 and X-3 at P8 per square meter, and lot X-2 at P3.50 per square meter) and assessed the defendant's sheds at P3,500. The trial court accepted these values. Procedural History: The plaintiff province appealed, insisting on a reduction of the price. Intervenors Godofredo Reyes and Domingo Lopez also appealed after their complaint in intervention was denied for being filed out of time and lacking a showing of necessity. The plaintiff submitted the commissioners' report to the court without recommendation, and the defendant objected to the plaintiff's request for a reduction. The Petition: The plaintiff province and the intervenors appealed the judgment of the trial court.
Issue(s)
Whether the trial court erred in accepting the commissioners' report without a proper hearing. Whether the English text of Section 246 of the Code of Civil Procedure should prevail over the Spanish text.
Ruling
The judgment appealed from is set aside, and the record is remanded to the court of origin for reopening and a hearing on the commissioners' report, allowing the appellants and other interested parties to be heard.
Ratio Decidendi
On the necessity of a hearing on the commissioners' report: The law intends for a proper hearing, with both parties present, to be held upon the commissioners' report in condemnation proceedings. Even if both parties agree with the report, this acquiescence must be recorded during such a hearing. The record did not show that a hearing was actually held, despite the defendant's request and the court's assignment of a date, as the plaintiff submitted the report without recommendation and the defendant objected to the plaintiff's request for reduction. This procedural defect violates the due process guarantees afforded to the party whose property is sought to be expropriated. On the prevailing text of the Code of Civil Procedure: While the original Spanish text of Section 246 of the Code of Civil Procedure states that the court "may accept" the report after reading it, the English text clearly states that the court "shall, upon hearing accept the same." In cases where a law was published by the Civil Commission, such as the Code in question, the English text must prevail in the interpretation, except when there is ambiguity, omission, or mistake, in which case the Spanish text may be consulted. Therefore, the English text mandating a hearing is controlling.
Main Doctrine
In condemnation proceedings, a hearing on the commissioners' report must be held, and the English text of the Code of Civil Procedure prevails in case of conflict with the Spanish text.