GR 191448; (November, 2011) (Digest)
G.R. No. 191448; November 16, 2011
REPUBLIC OF THE PHILIPPINES represented by the Department of Public Works and Highways (DPWH), Petitioner, vs. SPS. TAN SONG BOK and JOSEFINA S. TAN, et al., Respondents.
FACTS
On November 10, 2000, the Republic of the Philippines, represented by the Toll Regulatory Board (TRB), filed a complaint for expropriation of eight (8) parcels of land in Pampanga to become part of the Luzon Expressway (NLE) Project. A Writ of Possession was issued on April 18, 2002. A Committee on Appraisals was created, which submitted a Consolidated Committee Report on September 27, 2002, recommending specific amounts per square meter as just compensation for each lot, ranging from ₱3,650 to ₱4,400. The petitioner filed a Comment/Objection, arguing the recommended prices lacked sufficient basis as no documents like deeds of sale were presented, and factors like tax declarations and zonal valuation were not considered. The respondents argued the committee’s recommendations were based on the zonal value from a BIR certification, the latest recorded sale price, verification with local offices, and an ocular inspection, and that the committee members were experts. The Regional Trial Court (RTC), in its April 14, 2004 Decision, adopted the committee’s recommendations as the just compensation. The Court of Appeals (CA) affirmed the RTC decision with modification in its February 19, 2010 Decision. The petitioner elevated the case to the Supreme Court via a petition for review.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s determination of just compensation based on the Committee on Appraisals’ report.
RULING
The Supreme Court DENIED the petition and AFFIRMED the assailed Court of Appeals Decision. The Court held that the determination of just compensation is a judicial function. The trial court, in adopting the committee’s report, did not rely solely on the commissioners’ recommendations but made an independent evaluation of the facts and the evidence on record. The committee’s findings, which were based on the zonal valuation from the BIR, the latest recorded sale price in the area, verification with local offices, and an ocular inspection, provided a sufficient factual basis. The Court found no reversible error in the CA’s decision, as the factual findings of the trial court, especially when affirmed by the CA, are generally conclusive and binding. The petition raised factual issues that are not proper in a petition for review under Rule 45.