GR 173520; (January, 2013) (Digest)
G.R. No. 173520 ; January 30, 2013
NATIONAL POWER CORPORATION, Petitioner, vs. SPOUSES RODOLFO ZABALA and LILIA BAYLON, Respondents.
FACTS
Petitioner National Power Corporation (NPC) filed a complaint for eminent domain to acquire an easement of right-of-way over portions of respondents’ property for its 230 KV Limay-Hermosa Transmission Lines Project. The spouses Zabala moved to dismiss, arguing the taking was not the least burdensome means and that the assessed value used for the provisional deposit was outdated. The Regional Trial Court (RTC) appointed commissioners to determine just compensation.
The commissioners initially recommended compensation at ₱150 per square meter. Upon motions from both parties, the RTC recommitted the report. The commissioners then submitted a Final Report recommending ₱500 per square meter. The RTC, however, rendered a Partial Decision fixing compensation at ₱150 per square meter, rejecting the higher valuation. The Court of Appeals affirmed the RTC’s decision.
ISSUE
Whether the courts a quo erred in fixing just compensation at ₱150 per square meter instead of the ₱500 per square meter recommended in the commissioners’ Final Report.
RULING
The Supreme Court granted the petition and remanded the case to the RTC for proper determination of just compensation. The core legal principle is that the determination of just compensation is a judicial function. Legislative enactments or executive issuances prescribing formulas or methods for its computation are not binding on courts and serve only as guidelines.
The RTC erred in disregarding the commissioners’ Final Report without a valid, articulated cause. The Court emphasized that while a trial court is not bound to accept a commissioners’ report, it may not capriciously or arbitrarily reject it. Under Section 8, Rule 67 of the Rules of Court, a court may accept, reject, or recommit a commissioners’ report “for cause shown.” Here, the RTC’s Partial Decision provided no factual or legal justification for rejecting the Final Report’s ₱500 valuation and reverting to the initial ₱150 figure. This constituted a reversible error. The case was remanded to the RTC to evaluate the evidence, including the Final Report, and to determine just compensation based on the relevant factors such as the property’s character, its value at the time of taking, and the consequential benefits or damages, ensuring the amount is fair and in accordance with established jurisprudence.