G.R. No. L-13684; July 26, 1960
Republic of the Philippines, plaintiff-appellant, vs. Francisco Yaptinchay, et al., defendants-appellees.

FACTS

On September 15, 1948, the Republic of the Philippines, through the Rural Progress Administration (later succeeded by the Land Tenure Administration), instituted condemnation proceedings to expropriate multiple parcels of land in Carmona, Cavite, for subdivision and sale to tenant-occupants. The landowners did not object to the expropriation. The court appointed a committee of three to determine the market value. After a hearing, the committee chairman and one member, noting that tenants had taken possession by force before World War II, opined compensation should be based on the 1940 market value. Due to a lack of evidence for 1940 values, they considered the landowners’ 1942 sworn tax declarations, which totaled P85,500, but recommended the court’s provisional value of P111,290 (less P10,220 for excluded lots) as full compensation. The third committee member, Eduardo Barretto, submitted a separate report recommending varying valuations per hectare for the different groups of properties, ranging from P1,700 to P4,500 per hectare and P0.70 per square meter for one residential lot. The trial court, in its June 28, 1956 decision, held that the landowners were deprived of possession only upon actual delivery to the plaintiff on September 21, 1950. Disregarding the commissioners’ recommendations, the court fixed compensation at P0.50 per square meter for residential land, P4,000 per hectare for irrigated lands, and P2,000 per hectare for unirrigated lands, with 6% interest from the date of delivery. The Republic appealed, contesting these amounts as excessive.

ISSUE

Whether the trial court erred in fixing the compensation for the expropriated properties at the stated amounts, which the appellant claims are higher than the owners’ demands and the commissioner’s recommendation.

RULING

The Supreme Court sustained the plaintiff-appellant’s contention and modified the compensation. The trial court’s valuation, based on prior expropriation cases in Naic and Bacoor, Cavite, was erroneous. For such prior sales to be competent proof of market value, the properties must be adjoining or within the same zone of commercial activity. The cited cases involved different time periods and localities (Bacoor and Naic) that are nearer to Manila and in the lowlands, and thus not commercially identifiable with the mountainous region of Carmona. The Court considered the demands of some landowners (e.g., P1,500 per hectare) and several deeds of sale for lands in Carmona executed in 1951 and 1959, which showed lower prices. The Court held that sentimental value or inconvenience to the owner is not a compensable element. It declared reasonable compensation to be: P1,000 per hectare for irrigated lands with sugar quota; P800 per hectare for irrigated lands without quota and unirrigated lands with quota; P600 per hectare for unirrigated lands without sugar quota; and P0.50 per square meter for residential lands. The landowners were also entitled to legal interest on unpaid amounts from September 21, 1950 (date of delivery of possession) until actual payment. The decision was affirmed with this modification.