GR 193828; (March, 2017) (Digest)
G.R. No. 193828 March 27, 2017
Republic of the Philippines, represented by the Manila International Airport Authority (MIAA), Petitioner vs. Heirs of Eladio Santiago c/o Sabas Santiago and Jerry T. Yao, Respondents
FACTS
The Manila International Airport Authority (MIAA) filed a complaint for expropriation to acquire fragments of two parcels of land in Parañaque City for installing runway approach lights. The properties involved were a 180-square-meter portion of a lot owned by the Heirs of Eladio Santiago and a 540-square-meter portion of a lot owned by Jerry T. Yao. MIAA alleged that negotiations failed because the respondents insisted on the sale of their entire properties, which exceeded the project’s needs. The Parañaque City zonal value was ₱3,000 per square meter.
The respondents contested the expropriation and valuation. The Heirs of Santiago claimed a BIR zonal value of ₱30,000 per square meter and demanded payment for consequential damages. Yao argued the expropriation would render adjacent areas useless due to aircraft operations and claimed a market value of ₱10,000 per square meter, also seeking compensation for a bridge and other damages. Commissioners were appointed but failed to agree on just compensation, submitting disparate appraisals ranging from ₱2,500 to ₱15,000 per square meter.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s determination of just compensation.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ decisions. The Court emphasized that the determination of just compensation is a judicial function. While commissioners’ findings are advisory, the trial court is not bound by them and must independently arrive at a value based on the evidence. The RTC validly fixed compensation at ₱4,500/sq.m. for the Santiago property and ₱5,900/sq.m. for the Yao property.
The legal logic rests on the principle that just compensation is the full and fair equivalent of the property taken, considering its fair market value at the time of taking. The RTC correctly based its valuation on the report of the City Assessor of Parañaque (₱5,900/sq.m.), which it found most credible and comprehensive. The Court found no abuse of discretion, as the RTC’s order detailed its evaluation of all commissioner reports, the properties’ nature, and their relevant market values. The valuation was supported by substantial evidence, including the City Assessor’s data and the Parañaque City Ordinance. The Supreme Court upheld the factual findings of the lower courts, noting that factual determinations in just compensation cases are generally conclusive when supported by evidence.