GR 206702; (June, 2017) (Digest)
G.R. No. 206702 , June 7, 2017
Republic of the Philippines, represented by the National Irrigation Administration, Petitioner, vs. Rolando C. Cebuan, Ruben C. Cebuan, Eric C. Cebuan, Samuel C. Baring, Beatrice A. Low, Leonore L. De La Serna and Heirs of Lorenzo Umbaad, Respondents.
FACTS
The National Irrigation Administration (NIA) initiated expropriation proceedings for parcels of land in Butuan City for an irrigation project. NIA’s complaint valued the properties based on BIR zonal valuations, totaling PhP60,094.50 for 11,737 sq. m. The landowners generally agreed to the expropriation but demanded compensation of at least PhP300 per square meter. A Board of Commissioners was constituted, which recommended fair market values ranging from PhP45 to PhP120 per sq. m. and assessed consequential damages and benefits.
The Regional Trial Court (RTC) adopted the Commissioners’ Report, rejecting NIA’s argument that compensation should be based on the original purchase price of PhP0.90 per sq. m. The RTC also awarded unrealized income for lost agricultural produce to several landowners. The Court of Appeals (CA) affirmed the adoption of the Commissioners’ recommended values but deleted the award for unrealized income. The CA, however, remanded the case to the RTC, finding that the landowners had not been fully paid for improvements on their properties and for the court to make a final determination of just compensation.
ISSUE
Whether the Court of Appeals erred in remanding the case to the RTC for a final determination of just compensation.
RULING
The Supreme Court denied the petition and affirmed the CA’s decision. The legal logic is anchored on the fundamental nature of just compensation in expropriation. Just compensation is the full and fair equivalent of the property taken from the owner. Its determination is a judicial function, and courts are not bound by the valuations proposed by any party, including the government. The Commissioners’ Report, which the RTC adopted, served as an advisory basis but did not constitute a final and executory judgment on just compensation.
The remand was proper because the records indicated that payments made by NIA to some landowners were only for damages to crops and improvements for limited periods, not for the full value of the land and permanent improvements taken. Furthermore, the CA correctly observed that the RTC’s Partial Judgment did not fully adjudicate all components of just compensation for all affected landowners. A remand allows the trial court to conduct further proceedings, if necessary, to ascertain the complete just compensation—encompassing the fair market value of the land, the value of improvements, consequential damages, and legal interest—in accordance with evidence and jurisprudence. This ensures the constitutional guarantee that payment is not merely partial but truly equivalent to the loss suffered by the property owner.