GR 129998; (December, 1998) (Digest)
G.R. No. 129998 December 29, 1998
NATIONAL POWER CORPORATION, petitioner, vs. LOURDES HENSON, JOSEFINA HENSON, JESUSA HENSON, CORAZON HENSON, ALFREDO TANCHIATCO, BIENVENIDO DAVID, MARIA BONDOC CAPILI, and MIGUEL MANOLOTO, respondents.
FACTS
The National Power Corporation (NPC) filed a complaint for eminent domain to acquire five parcels of agricultural land in Mexico, Pampanga, with an aggregate area of 58,311 square meters, for the expansion of its Mexico Sub-Station. The respondents, being the registered owners or claimants, did not contest NPC’s right to expropriate but disputed the valuation. The trial court fixed a provisional value of P100.00 per square meter, which NPC deposited, and a writ of possession was issued, placing NPC in control of the property on September 11, 1990. The court appointed three commissioners to ascertain just compensation. Their reports recommended values of P350.00, P375.00, and P170.00 per square meter, respectively. Without conducting a hearing on these reports, the trial court fixed just compensation at P400.00 per square meter for an area of 63,220 square meters, with legal interest from September 11, 1990. The Court of Appeals affirmed this decision but deleted the award for attorney’s fees.
ISSUE
What constitutes the correct determination of just compensation for the expropriated properties?
RULING
The Supreme Court modified the decision, holding that the trial court committed a reversible error by fixing just compensation without conducting a hearing on the commissioners’ reports. The legal logic is grounded in the fundamental requirement that just compensation must be based on all relevant facts and equitable principles. The court emphasized that while commissioners’ reports are advisory, a hearing is essential to allow the parties to contest the findings, present contrary evidence, and ensure the court’s determination is informed and fair. The trial court’s failure to hold such a hearing deprived the parties of due process and rendered its valuation arbitrary.
Consequently, the Supreme Court set aside the valuation of P400.00 per square meter. It adopted the highest recommendation from the commissioners’ reports—P375.00 per square meter—as the fair market value, finding this figure to be adequately supported. The Court ordered NPC to pay the respondents based on this rate for their respective land areas, deducting the amounts already withdrawn from the provisional deposit. Legal interest was set at 6% per annum from September 11, 1990, until the finality of the decision, and 12% per annum thereafter on any unpaid balance until full settlement. This ruling ensures compensation is both fair and procedurally sound.