GR 221995; (October, 2018) (Digest)
G.R. No. 221995 . October 03, 2018
REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE TOLL REGULATORY BOARD, PETITIONER, V. SPOUSES TOMAS C. LEGASPI AND RUPERTA V. ESQUITO, PABLO VILLA, TEODORA VILLA, FLORENCIO VILLA, AND RURAL BANK OF CALAMBA (LAGUNA), INC., RESPONDENTS.
FACTS
The Republic, through the Toll Regulatory Board, filed a complaint for expropriation over several lots in Calamba, Laguna, totaling 13,002 square meters, for the South Luzon Tollway Extension Project. For the issuance of a writ of possession, petitioner deposited P3,120,480 based on a BIR zonal valuation of P240 per square meter. Respondents contested this, asserting the lots were commercial with a zonal value of P2,500 per square meter and claimed payment for improvements. The trial court ordered petitioner to deposit the corrected provisional amount of P32,505,500 and pay for the improvements. A Board of Commissioners was constituted to determine just compensation.
The Board of Commissioners submitted a report with varying recommendations: P3,000, P2,500, and P4,500 per square meter. The trial court initially fixed just compensation at P3,500 per square meter. Upon petitioner’s motion, a different judge reconsidered and lowered it to P240 per square meter. Subsequently, another judge reinstated the original P3,500 valuation. The Court of Appeals affirmed this reinstatement, prompting the petitioner’s appeal to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s determination of just compensation at P3,500 per square meter.
RULING
The Supreme Court denied the petition and affirmed the assailed Court of Appeals decision. The Court emphasized that the determination of just compensation is a judicial function, and factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally binding and conclusive. The petitioner failed to prove that the case fell under any recognized exception to this rule.
The legal logic is anchored on the nature of just compensation, which is the full and fair equivalent of the property taken at the time of its taking. The Court clarified that the BIR zonal valuation, used for the provisional deposit under Republic Act No. 8974 , is not conclusive for determining final just compensation. The trial court correctly relied on the Commissioners’ Report, which considered the property’s character, its classification within a Growth Management Zone per a municipal ordinance, its potential use, and the values of adjacent properties. The valuation of P3,500 per square meter was a reasoned conclusion based on this evidence, not on mere speculation. The Court found no reversible error in the lower courts’ appreciation of the facts and application of the legal principles governing eminent domain.