GR 113194; (March, 1996) (Digest)
G.R. No. 113194 March 11, 1996
NATIONAL POWER CORPORATION, petitioner, vs. COURT OF APPEALS and MACAPANTON MANGONDATO, respondents.
FACTS
In 1978, the National Power Corporation (NAPOCOR) took possession of a 21,995-square-meter parcel of land in Marawi City owned by Macapanton Mangondato, believing it was part of public land reserved for its hydroelectric project. NAPOCOR had paid “financial assistance” to Marawi City for the property. Mangondato demanded compensation, asserting his ownership under a Transfer Certificate of Title. NAPOCOR refused, maintaining the land was public. Over a decade later, NAPOCOR acceded that the land was privately owned by Mangondato.
Subsequent negotiations for just compensation failed. NAPOCOR’s board initially resolved to pay P100 per square meter, while Mangondato insisted on P300 per square meter plus 12% interest from 1978. Failing an amicable settlement, NAPOCOR filed a complaint for eminent domain in 1992. The Regional Trial Court fixed just compensation at P1,000 per square meter, condemning the property in favor of NAPOCOR effective July 1992, and ordered payment of monthly rentals from 1978. The Court of Appeals affirmed this decision.
ISSUE
At what point in time should the value of the land subject of expropriation be computed for the determination of just compensation: at the date of the actual “taking” or at the date of the filing of the complaint?
RULING
The Supreme Court ruled that just compensation must be determined as of the date of the actual taking of the property. The Court affirmed the appellate court’s decision, which upheld the trial court’s use of the value at the time of taking, consistent with Section 4, Rule 67 of the Rules of Court. The general rule is that the value should be fixed as of the time of the taking, not the filing of the complaint. This rule applies unless the expropriator commits unreasonable delay, causing the owner’s loss, which is not present here.
The Court rejected NAPOCOR’s argument that valuation should be as of the filing date in 1992. The “taking” occurred in 1978 when NAPOCOR entered and occupied the land without the owner’s consent, constructing permanent improvements. Just compensation aims to indemnify the owner fully for the loss at that point. The trial court correctly considered the property’s nature, its value, and all consequential damages from the taking. The commissioners’ reports, which considered factors like the property’s highest and best use and market trends, supported the valuation. The award of legal interest on the compensation from 1978 was proper, though the interest on unpaid rentals was reduced to the legal rate of 6% per annum.