GR 75979; (January, 1990) (Digest)
G.R. No. 75979 ; January 17, 1990
RAYMUNDO MARABELES and PACIANO DELALAMON, petitioners, vs. COURT OF APPEALS and the REPUBLIC OF THE PHILIPPINES, represented by LEYTE SAB-A BASIN DEVELOPMENT AUTHORITY, respondents.
FACTS
The Leyte Sab-a Basin Development Authority instituted an expropriation proceeding to acquire land for an industrial estate pursuant to Letter of Instructions No. 962. The Regional Trial Court of Ormoc City issued an order of condemnation and appointed commissioners under Rule 67 of the Rules of Court to determine just compensation. The commissioners submitted their report. While most defendants acquiesced, petitioners Raymundo Marabeles and Paciano Delalamon contested the report and presented their own evidence. The trial court rendered a decision ordering the Authority to pay Marabeles P45,000 and Delalamon P19,000 for their respective properties.
On appeal, the Court of Appeals not only affirmed the trial court but also reduced the compensation awarded to the petitioners. The appellate court applied Presidential Decree No. 464, as amended, which prescribed that just compensation shall not exceed the market value declared by the owner in the tax declaration or the assessor’s value, whichever is lower. Since the values in the petitioners’ tax declarations (P6,470 for Marabeles and P10,310 for Delalamon) were lower than the commissioners’ valuations, the Court of Appeals modified the award to these amounts.
ISSUE
Whether the Court of Appeals erred in applying Presidential Decree No. 464 to determine just compensation in the expropriation case.
RULING
Yes, the Court of Appeals committed reversible error. The Supreme Court reversed the appellate court’s decision and reinstated that of the trial court. The legal logic is anchored on the constitutional principle that the determination of just compensation in eminent domain cases is a judicial function. In the landmark case of Export Processing Zone Authority v. Dulay, the Court had already declared the pertinent provisions of P.D. No. 464, as amended, unconstitutional and void. The decree was struck down for being an impermissible encroachment on judicial prerogatives, as it effectively relegated the court’s role to a mere ministerial act of selecting the lower value between the owner’s declared value and the assessor’s value. This usurped the court’s constitutional duty to independently ascertain what is “just” compensation, rendering the judicial proceeding a mere formality. The Court has consistently reiterated this doctrine in subsequent cases.
Consequently, the Court of Appeals’ reliance on the unconstitutional decree was fundamentally flawed. The trial court correctly followed the procedure under Rule 67 of the Rules of Court by appointing commissioners to aid in the valuation. The factual findings of these commissioners, as approved by the trial court, stand unreviewed, as the Supreme Court found no compelling reason to disturb them on appeal. Therefore, the compensation initially determined by the trial court, based on the judicial process outlined in Rule 67, is reinstated as the constitutionally sound valuation.