GR 186069; (January, 2013) (Digest)
G.R. No. 186069 ; January 30, 2013
SPOUSES JESUS L. CABAHUG AND CORONACION M. CABAHUG, Petitioners, vs. NATIONAL POWER CORPORATION, Respondent.
FACTS
Petitioners Spouses Cabahug owned two parcels of land in Leyte. Respondent NPC, for its Leyte-Cebu Interconnection Project, initially filed an expropriation case but later opted to settle by paying an easement fee under Section 3-A of Republic Act No. 6395 . The Provincial Appraisal Committee fixed the land value at P45.00 per square meter. On November 9, 1996, Jesus Cabahug executed Right of Way Grant documents in favor of NPC, receiving specified easement fees for portions of the land. Paragraph 4 of the grant reserved the option to seek additional compensation for the easement fee based on the Supreme Court’s ruling in NPC v. Gutierrez.
In 1998, the spouses filed a complaint for just compensation, claiming total deprivation of the land’s use and demanding payment of the balance based on the P45.00/sq.m valuation, minus the easement fees already paid. The RTC ruled in their favor, applying the Gutierrez doctrine that such an easement constitutes a taking compensable as eminent domain. The Court of Appeals reversed the RTC, holding that the easement was already consummated by the 1996 grant and acceptance of payment, and that allowing further compensation would violate the contract and result in unjust enrichment.
ISSUE
Whether the Spouses Cabahug are entitled to full payment of just compensation for their property, over and above the easement fees already received under the Right of Way Grant.
RULING
No. The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is anchored on the nature of the agreement and the specific reservation clause. The Right of Way Grant executed by the petitioners was a voluntary contract, not a product of expropriation proceedings. The consideration paid was explicitly for an easement of right of way, as authorized under Section 3-A of RA 6395.
Crucially, the reservation in Paragraph 4 of the grant only pertained to a claim for additional compensation for the easement fee, not a claim for full just compensation as for a taking of title. The Court distinguished the case from NPC v. Gutierrez, where the property owners did not execute any similar deed of grant and were held entitled to just compensation due to a permanent and indefinite deprivation equivalent to expropriation. Here, by voluntarily entering into the agreement and accepting the stipulated easement fees, the petitioners are bound by its terms. To allow them to recover full market value after the contract was consummated would sanction a violation of their contractual commitment and constitute unjust enrichment. The contract defined the compensation for the easement, and the reservation clause did not convert the transaction into a de facto expropriation requiring full indemnity.