G.R. No. 224324 . January 22, 2020.
NATIONAL POWER CORPORATION, PETITIONER, V. HEIRS OF SALVADOR SERRA SERRA, HEIRS OF GREGORIO SERRA SERRA, MARGARITA SERRA SERRA, FRANCISCA TERESA SERRA SERRA, FRANCISCO JOSE SERRA SERRA, SPOUSES PRIMITIVO HERNAEZ AND PAZ BACOL, SPOUSES BERNARDINO MONCERA AND ROGACIANA HERNAEZ, SPOUSES AMBROSIO FORTALIZA AND LUISA HERNAEZ; BANK OF THE PHILIPPINE ISLANDS, REPRESENTED BY ITS MANAGER, LUIS A. PUENTEVELLA AND ARSENIO AL ACUÑA, RESPONDENTS.

FACTS

Petitioner National Power Corporation (NAPOCOR) filed a Complaint for eminent domain on October 16, 1998, before the Regional Trial Court (RTC) of Kabankalan City to acquire an easement of right of way over portions of parcels of land (Lot Nos. 2746 and 1316, later amended to include Lot 2747) owned by respondents for its Kabankalan-Maricalum 138KV Transmission Line Island Grid Project. After depositing the provisional value, NAPOCOR was placed in possession of the properties on August 3, 1999. The RTC, after proceedings including the submission of a Board of Commissioners’ report, rendered a Decision on May 26, 2011, ordering expropriation and fixing just compensation at P18,919,113.75, less the initial deposit. The RTC based its valuation on factors including the 1997 zonal values, the properties’ actual use (sugarcane despite residential classification), and the extent of disturbance. The Court of Appeals (CA) affirmed the RTC Decision with modification, ordering legal interest of 12% per annum on the balance from the time of filing of the complaint until fully paid. NAPOCOR filed a Petition for Review, arguing that the just compensation should be based solely on the property’s value and character at the time of the filing of the complaint in 1998, and contending that the courts a quo erroneously considered improvements existing in 2006.

ISSUE

Whether the amount of just compensation awarded to respondents should be based on the prevailing price and character of the property at the time of the filing of the Complaint for eminent domain in 1998.

RULING

The Supreme Court DENIED the petition and AFFIRMED the CA Decision with MODIFICATION regarding the imposed interest rates. The Court held that the RTC properly ascertained the value and character of the property as of the time of the filing of the complaint in 1998, pursuant to Rule 67 of the Rules of Court and jurisprudence. The Court found NAPOCOR’s allegation that the RTC considered improvements as of 2006 to be without basis, as a complete reading of the CA decision showed that the RTC independently arrived at its valuation based on the relevant period and did not adopt the respondents’ 2006-based proposal. The Court, being not a trier of facts, found no ground to reverse the factual findings of the lower courts. On the interest, the Court modified the CA’s imposition: legal interest at 12% per annum on the balance of P18,661,113.75 shall run from August 3, 1999 (date of taking) until June 30, 2013; thereafter, at 6% per annum from July 1, 2013, until the finality of the resolution; and the total just compensation shall earn 6% per annum from finality until full payment, following applicable circulars and jurisprudence.