GR 156093; (February, 2007) (Digest)
G.R. No. 156093 . February 2, 2007.
NATIONAL POWER CORP., Petitioner, vs. SPOUSES NORBERTO AND JOSEFINA DELA CRUZ, METROBANK, Dasmariñas, Cavite Branch, REYNALDO FERRER, and S.K. DYNAMICS MANUFACTURER CORP., Respondents.
FACTS
Petitioner National Power Corporation (NAPOCOR) filed a complaint for eminent domain to acquire an easement of right-of-way over portions of land in Cavite for a transmission line project. The affected properties, owned by respondents, totaled 84.425 square meters. The trial court issued a writ of possession after NAPOCOR deposited the provisional value. A Board of Commissioners was constituted to determine just compensation for the property of respondent S.K. Dynamics.
The commissioners submitted a report recommending a fair market value of PhP 10,000 per square meter. The report was based on an ocular inspection and analysis of the property’s location, neighborhood description, and highest and best use. The record showed that the commissioners did not conduct hearings, issue notices to parties, or allow the introduction of evidence. Petitioner was not notified of the report’s filing nor given an opportunity to object. The trial court adopted the commissioners’ valuation in its Order.
ISSUE
Whether the trial court committed reversible error in fixing just compensation based solely on the commissioners’ report without conducting a hearing or allowing the parties to present evidence.
RULING
Yes. The Supreme Court reversed the decisions of the lower courts. The determination of just compensation is a judicial function. While commissioners’ reports are advisory, courts are not bound to accept them and must independently evaluate the evidence. The trial court’s reliance on the report was erroneous because the commissioners’ proceedings were fundamentally flawed. They failed to conduct hearings, receive evidence from the parties, or provide notice—violating basic procedural due process.
The Court emphasized that just compensation must be based on all relevant facts and established rules. The trial court abdicated its duty by merely adopting the commissioners’ findings without conducting its own hearing to examine the basis of the valuation, especially given NAPOCOR’s timely objection. Consequently, the case was remanded to the trial court to receive evidence, conduct a proper hearing, and determine just compensation in accordance with law and jurisprudence, ensuring both parties are afforded due process.