GR 180979; (December, 2010) (Digest)
G.R. No. 180979 ; December 15, 2010
NATIONAL POWER CORPORATION, Petitioner, vs. TERESITA DIATO-BERNAL, Respondent.
FACTS
Petitioner National Power Corporation (NAPOCOR) filed an expropriation suit to acquire an easement of right of way over respondent Teresita Diato-Bernal’s 946-square meter property in Imus, Cavite, for its transmission line project. The parties executed a partial compromise agreement, settling the location and size of the affected area (29.25 square meters) but leaving the determination of just compensation for judicial resolution. The Regional Trial Court (RTC) appointed three commissioners to assist in valuation.
The commissioners submitted a report recommending just compensation at ₱10,000.00 per square meter based on the property’s fair market value. NAPOCOR opposed this, arguing the report lacked substantiation by official documents or deeds of sale from neighboring lots. It insisted compensation should be only ₱3,500.00 per square meter, citing a 1995 resolution from the Provincial Appraisal Committee of Cavite (PAC-Cavite). The RTC adopted the commissioners’ recommendation, and the Court of Appeals affirmed the RTC’s order.
ISSUE
Whether the Court of Appeals erred in affirming the RTC’s determination of just compensation at ₱10,000.00 per square meter.
RULING
The Supreme Court granted the petition and remanded the case for proper determination of just compensation. The Court first addressed respondent’s procedural objection, ruling that the petition raised a question of law—specifically, whether the lower courts correctly applied the legal standards for determining just compensation—which is reviewable under Rule 45.
On the merits, the Court held that the commissioners’ report, which the RTC solely relied upon, was legally insufficient. Citing Republic v. Santos, the Court emphasized that a commissioners’ report not based on any documentary evidence is hearsay and cannot serve as a valid basis for valuation. Here, the report contained only a bare recommendation without reference to supporting data such as tax declarations, actual sales, or independent appraisal methods. Consequently, the RTC’s adoption of the report lacked a factual and legal foundation.
The Court further clarified that while the PAC-Cavite resolution cited by NAPOCOR could be a factor in the judicial determination of just compensation, it could not be the sole basis, as the determination of just compensation is a judicial function. The absence of a properly substantiated commissioners’ report or any other competent valuation evidence rendered the RTC’s order and the CA’s affirmance void. Thus, a remand was necessary for the trial court to receive and evaluate appropriate evidence in accordance with established jurisprudence on expropriation valuation.