GR 203608; (December, 2018) (Digest)
G.R. No. 203608 . December 05, 2018
REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE DEPARTMENT OF PUBLIC WORKS AND HIGHWAYS, PETITIONER, VS. THE HEIRS OF SPOUSES FLAVIANO S. MAGLASANG AND SALUD ADAZA MAGLASANG, RESPONDENTS.
FACTS
The Republic, through the DPWH, filed a complaint for expropriation over a 68-square-meter parcel of land owned by the respondents for a flood mitigation project. The Ormoc City Appraisal Committee valued the land at P1,000 per square meter. The respondents failed to file their comment/opposition and were declared in default, allowing the petitioner to present evidence ex parte. The petitioner deposited P68,000, representing 100% of the appraised value, and was granted a writ of possession. The respondents later moved for reconsideration and were allowed to present evidence on just compensation.
Subsequently, the respondents’ counsel orally manifested that the case was similar to Republic v. Larrazabal, involving a contiguous property decided by the same trial court. The RTC allowed the respondents to submit the decision and commissioners’ report from the Larrazabal case. Adopting the Larrazabal valuation of P17,000 per square meter, the RTC ordered the petitioner to pay just compensation of P1,156,000. The Court of Appeals affirmed the RTC’s decision, holding that the trial court correctly took judicial notice of the Larrazabal proceedings.
ISSUE
Whether the Regional Trial Court properly took judicial notice of the Larrazabal case to determine the just compensation for the respondents’ property.
RULING
No. The Supreme Court ruled that the RTC erred in taking judicial notice of the Larrazabal case to ascertain just compensation. The general rule is that courts cannot take judicial notice of evidence presented in another case, even if pending before the same court. While exceptions exist, they did not apply here. The respondents merely alleged contiguity without presenting evidence to substantiate that the properties were similarly situated in classification, condition, and value. The Larrazabal properties had significant improvements, whereas the only competent valuation for the subject land was the Ormoc City Appraisal Committee’s report of P1,000 per square meter for commercial lots.
Crucially, just compensation must be based on the value of the property at the time of its taking or the filing of the complaint. The RTC’s reliance on the Larrazabal valuation, without a proper hearing where the petitioner could contest its applicability, violated procedural due process. The petitioner was deprived of its right to cross-examine evidence and present countervailing proof regarding the property’s value. Therefore, the CA decision was set aside, and the valuation must be determined based on proper evidence presented in a hearing on the merits.