GR 190453; (February, 2020) (Digest)
G.R. No. 190453 February 26, 2020
REPUBLIC OF THE PHILIPPINES, PETITIONER, VS. JORGE CASTILLO, SOFIA SOLIS-ACHACOSA, ALIPIO FERNANDEZ, SR., EMILIANA FERNANDEZ, CASIMERA FERNANDEZ, CONCEPCION FERNANDEZ, JUANA GALVAN, ESTELA CORPUZ FERNANDEZ, GERMANA SUAREZ, AND BENJAMIN FERNANDEZ, RESPONDENTS.
FACTS
On September 5, 1980, the Solicitor General, on behalf of the Republic of the Philippines (RP), filed a Complaint for Expropriation against the respondents, who are co-owners of a property in Dagupan City with an area of 11,585 square meters. Respondents opposed the valuation, arguing it should be based on the current fair market value in 1980, not a 1974 tax declaration. The case was archived in 1981 and later dismissed in 1986 for lack of prosecution. It was revived in 1987. On February 2, 1989, RP filed an Amended Complaint alleging the Dagupan City National High School had been in continuous possession since 1947, valuing the property at fifty centavos per square meter at that time. After trial, the RTC initially dismissed the Amended Complaint in 1992, but the CA reversed and remanded the case in 1999 for determination of just compensation. On July 6, 2004, the RTC fixed just compensation at P15,000 per square meter based on the fair market value as of February 2, 1989 (the date of the Amended Complaint). The CA, in its February 27, 2009 Decision, reversed the RTC, remanded the case for trial with commissioners to determine just compensation, but agreed that the valuation date should be February 2, 1989, not the alleged 1947 taking. RP elevated the case via Petition for Review on Certiorari.
ISSUE
1. What is the reckoning date for the computation of just compensation: (a) date of taking in 1947; (b) date of the filing of the original Complaint in 1980; or (c) date of filing of the Amended Complaint in 1989?
2. Whether or not the Solicitor General had the authority to file the expropriation case on behalf of the Republic of the Philippines.
RULING
1. On the reckoning date for just compensation: The Supreme Court ruled that just compensation should be determined as of the time of the filing of the original Complaint on September 5, 1980. The Court held that the filing of the complaint marks the point at which the owner is deprived of the beneficial use of the property. The Amended Complaint did not introduce a new cause of action; it merely amplified the allegations in the original complaint. The alleged “taking” in 1947 was not sufficiently proven, as the petitioner’s evidence, primarily the testimony of the school principal, was deemed vague and unsupported. Therefore, the valuation date is the filing of the original complaint in 1980, not the filing of the Amended Complaint in 1989 or the alleged 1947 taking.
2. On the authority of the Solicitor General: The Supreme Court ruled that the Solicitor General had the authority to file the expropriation complaint. At the time of its institution in 1980, Presidential Decree No. 478 defined the powers of the Office of the Solicitor General, including representing the government in all civil actions and special proceedings before any court or tribunal. The Solicitor General’s authority to initiate the case emanated from this decree.
DISPOSITIVE PORTION:
The Petition is PARTLY GRANTED. The case is REMANDED to the court of origin: (a) to determine just compensation as per valuation of the subject property at the time of the filing of the original Complaint on September 5, 1980; and (b) to conduct a trial with the aid of commissioners and in accordance with Rule 67 of the Rules of Court and applicable jurisprudence.