G.R. No. 226021 . July 24, 2019.
REPUBLIC OF THE PHILIPPINES, represented by the DEPARTMENT OF PUBLIC WORKS AND HIGHWAYS, Petitioner, vs. GILDA A. BARCELON, HAROLD A. BARCELON, and HAZEL A. BARCELON, Respondents.

FACTS

On February 8, 2008, the Republic, through the DPWH, filed a complaint for expropriation before the RTC of Valenzuela to acquire a 52-square-meter parcel of land owned by the respondents, covered by TCT No. V-75179, for the C-5 Northern Link Road Project. The property had a zonal value of ₱2,750.00 per square meter and a one-storey residential house valued at ₱288,418.54. The petitioner deposited ₱413,418.54, and upon receipt, the RTC issued a writ of possession. A later order released an additional ₱18,000.00 to complete the 100% zonal value deposit required for possession.
The RTC constituted a Board of Commissioners to determine just compensation. The petitioner argued for compensation based on the zonal value of ₱2,750.00 per square meter, claiming the area was infested with informal settlers and had poor conditions. The respondents argued for a range of ₱10,000.00 to ₱15,000.00 per square meter, citing the property’s location in a high-intensity commercial zone and prevailing market value. The Board recommended just compensation at ₱10,000.00 per square meter and ₱288,418.54 for the improvement, considering valuations from prior expropriation cases for the same project involving nearby properties (Hobart Realty Development Corporation and Spouses Mapalad Serrano).
The RTC fixed just compensation at ₱9,000.00 per square meter (totaling ₱468,000.00 for the lot) and awarded the recommended amount for the improvement. It also ordered the petitioner to pay 12% interest per annum on the initial deposit from the filing of the complaint until its court deposit, and 12% interest on the unpaid balance from the filing until full payment. The petitioner appealed to the CA, questioning the just compensation amount and the interest.
The CA affirmed the RTC’s valuation of ₱9,000.00 per square meter, finding the RTC properly considered the Board’s findings and the proximity to properties in high-density commercial areas. It rejected the petitioner’s claim about informal settlers for lack of evidence and ruled that zonal valuation is only one index of fair market value. The CA modified the interest: 12% per annum on the deposit from filing until court deposit; 12% per annum on the balance from filing until June 30, 2013; and 6% per annum from July 1, 2013, until full payment. The CA denied the petitioner’s motion for reconsideration.

ISSUE

Did the Court of Appeals err in sustaining the amount of just compensation fixed by the Regional Trial Court?

RULING

No, the Court of Appeals did not err.
The Supreme Court ruled that the determination of just compensation is a judicial function and a question of fact. Just compensation is the full and fair equivalent of the property taken, equivalent to its market value at the time of taking. The Court is not a trier of facts, and factual findings of the trial court, when affirmed by the CA, are generally conclusive and binding. The petitioner failed to show any exceptional circumstance warranting a deviation from this rule.
The RTC and CA correctly considered the factors under Section 5 of the Rules of Court and relevant jurisprudence, not merely the property’s distance from other expropriated properties. The courts considered the Board of Commissioners’ report, which relied on competent evidence including the valuations from the Hobart Realty and Spouses Serrano cases for the same government project, as the expropriated properties were nearby. The petitioner’s claim that the area was infested with informal settlers was unsupported by evidence. Zonal valuation is merely one of the indices for determining fair market value and is not conclusive. The award of ₱9,000.00 per square meter was upheld as a factual determination supported by evidence. The modified interest rates imposed by the CA, in accordance with prevailing jurisprudence, were also affirmed.