GR 152436; (June, 2003) (Digest)
G.R. No. 152436; June 20, 2003
NATIONAL POWER CORPORATION, Petitioner, vs. SPOUSES IGMEDIO and LIWAYWAY CHIONG and the HEIRS OF AGRIFINA ANGELES, represented by FRANCISCO MERCURIO, Respondents.
FACTS
Petitioner National Power Corporation (NPC) filed a complaint for eminent domain to acquire an easement of right-of-way over portions of agricultural lands owned by respondents for its Northwestern Luzon Transmission Line Project. The respondents did not contest NPC’s right to expropriate but disputed the compensation. The trial court appointed commissioners to determine just compensation. Two commissioners recommended a fair market value of ₱500 per square meter for the land taken from the Heirs of Agrifina Angeles, while the third commissioner, appointed by NPC, recommended payment of only an easement fee based on a drastically lower valuation.
The trial court adopted the ₱500 per square meter valuation in its order directing NPC to pay the respondents. NPC filed a special civil action for certiorari with the Court of Appeals, arguing the trial court committed grave abuse of discretion by ordering payment without a formal expropriation order, adopting the commissioners’ report without a hearing, and ordering payment of full market value instead of a mere easement fee. The Court of Appeals dismissed the petition, prompting NPC to elevate the case to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s order directing NPC to pay just compensation based on the full market value of the land, as opposed to a limited easement fee.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision. The Court held that where the government agency’s act of entering and depriving the property owner of the beneficial use of their land amounts to a taking in the constitutional sense, the owner is entitled to compensation for the full market value, not merely a nominal easement fee. The legal logic is rooted in the constitutional guarantee of just compensation, which requires the payment of the full and fair equivalent of the property taken from the owner.
In this case, NPC’s construction of transmission lines, which prohibited the landowners from planting any vegetation or building any structures on the affected portions, effectively deprived them of all beneficial use and economic value of the land. This constituted a taking of the land itself, not a mere imposition of a simple easement. Consequently, the compensation must be based on the land’s full market value at the time of taking. The Court found the trial court’s reliance on the commissioners’ report, which recommended ₱500 per square meter, to be proper and in accordance with the evidence presented. NPC’s failure to timely object to the report or move for reconsideration of the trial court’s order estopped it from claiming denial of due process.