GR 194190; (January, 2017) (Digest)
G.R. No. 194190 , January 25, 2017
Republic of the Philippines, represented by the DPWH vs. Spouses Francisco R. Llamas and Carmelita C. Llamas
FACTS
The DPWH initiated an expropriation case in 1990 for the widening of Sucat Road. The Llamas Spouses, claiming their properties were affected but excluded from the original case, successfully intervened in 1994. They asserted that a total of 298 square meters from three lots was taken. The DPWH contested this, verifying that only 41 square meters from one lot was actually affected for the project. In 2007, the Regional Trial Court ordered compensation at ₱12,000 per square meter but only for the 41-square-meter portion. It denied payment for the remaining areas, declaring them to be subdivision road lots that the spouses “no longer owned” and which belonged to the community. The Court of Appeals reversed this in 2010, ordering compensation for the full 237 square meters claimed, inclusive of the road lots.
ISSUE
Whether the Llamas Spouses are entitled to just compensation for the areas designated as subdivision road lots that were taken for the public road widening project.
RULING
Yes. The Supreme Court affirmed the Court of Appeals’ decision, ruling that the Llamas Spouses are entitled to just compensation for the entire area taken, including the road lots. The legal logic is anchored on the constitutional guarantee of just compensation for private property taken for public use. The Court clarified that the act of donating subdivision road lots to the local government for public use does not automatically divest the owner of all proprietary rights. Ownership is transferred only upon the proper acceptance and formal donation of the lots. Crucially, the act of expropriation by the national government (DPWH) constitutes a distinct “taking” separate from any previous implied or inchoate donation for subdivision use. When the government permanently appropriates such property for a different public purpose (road widening), it effects a compensable taking from the registered owner. The registered titles of the Llamas Spouses constituted prima facie evidence of their ownership. Since the DPWH entered, permanently occupied, and used the land for a public purpose, all elements of a taking were present, obligating the government to pay just compensation for the entire area actually appropriated, regardless of its prior designation.