FACTS
The Republic of the Philippines, through the Department of Public Works and Highways (DPWH), instituted a complaint for expropriation over a 550-square-meter parcel of land in Kawit, Cavite for the Manila-Cavite Tollways Expressway Project (MCTEP), R-1 Extension Expressway, Segment 4. The registered owner of the land was Pacita Villao, while Carmienett Javier was later impleaded as the owner of the improvements constructed on the property. Pursuant to Republic Act No. 8974, the DPWH deposited the initial amounts corresponding to the Bureau of Internal Revenue (BIR) zonal valuation of the land and the assessed value of the improvements, after which the Regional Trial Court (RTC) issued a writ of possession in favor of the government.
To determine just compensation, the RTC appointed a Board of Commissioners (BOC) in accordance with Rule 67 of the Rules of Court. After conducting ocular inspections and considering the surrounding developments, comparable properties, and documentary evidence, the BOC recommended a valuation substantially higher than the amount initially deposited by the government. The RTC adopted the Commissioners' Report and fixed the amount of just compensation accordingly.
The DPWH appealed to the Court of Appeals (CA), arguing that the Commissioners' Report was unsupported by competent evidence and merely relied on valuations made in another expropriation case involving nearby properties. The CA nevertheless affirmed the RTC, prompting the Republic to elevate the case to the Supreme Court through a Petition for Review on Certiorari under Rule 45.
ISSUE
Whether or not the RTC and the Court of Appeals correctly relied on the Board of Commissioners' Report in determining the amount of just compensation for the expropriated property.
Whether or not the Commissioners complied with the standards for determining just compensation under Rule 67 of the Rules of Court and Section 5 of Republic Act No. 8974 (An Act to Facilitate the Acquisition of Right-of-Way for National Government Infrastructure Projects).
Whether or not the case should be remanded for a new determination of just compensation consistent with constitutional and statutory requirements.
HELD
The Supreme Court GRANTED the petition and REVERSED the decisions of the Court of Appeals and the Regional Trial Court. The Court held that the determination of just compensation is a judicial function mandated by Article III, Section 9 of the 1987 Constitution, which guarantees that private property shall not be taken for public use without just compensation. While courts may appoint commissioners under Rule 67 of the Rules of Court to assist in valuation, the commissioners' findings are merely advisory and do not relieve the trial court of its duty to independently evaluate the evidence before fixing just compensation.
The Court ruled that the Board of Commissioners' Report was insufficient to support the valuation adopted by the RTC. The report failed to adequately explain the factual and legal bases for the recommended valuation and substantially relied on the valuation made by another Board of Commissioners in a separate expropriation case involving neighboring properties. The Court emphasized that just compensation must be determined on the basis of the evidence presented in the particular case, considering the factors enumerated in Section 5 of Republic Act No. 8974, including the property's classification, current selling price of similar lands, zonal valuation, location, size, improvements, and other relevant circumstances.
The Court stressed that the valuation in another expropriation case cannot automatically serve as precedent because each property possesses distinct characteristics and each case involves different evidence. The constitutional requirement of just compensation demands an individualized assessment based on competent evidence presented by the parties. A commissioners' report unsupported by sufficient factual findings cannot serve as the sole basis for fixing compensation.
Accordingly, the Supreme Court remanded the case to the Regional Trial Court of Imus, Cavite for the proper determination of just compensation in accordance with Rule 67 of the Rules of Court, Section 5 of Republic Act No. 8974, and the constitutional requirement that property owners receive the full and fair equivalent of the property taken. The Court likewise directed that the final amount of just compensation shall earn legal interest of six percent (6%) per annum from the finality of the judgment fixing just compensation until full payment, consistent with prevailing jurisprudence.
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