GR 227960; (July, 2019) (Digest)
G.R. No. 227960 , July 24, 2019
Republic of the Philippines [represented by the DPWH], Petitioner, vs. Spouses Lorenzana Juan Darlucio and Cosme Darlucio, Respondents.
FACTS
The Republic, through the DPWH, filed a complaint to expropriate 413 square meters of the respondents’ land in Valenzuela City for the C-5 Northern Link Road Project. The respondents agreed to the expropriation but contested the offered compensation based on the zonal value of P3,450 per square meter. They demanded just compensation based on the prevailing market value, alleging their industrially categorized land had a value between P10,000 to P15,000 per square meter. A Board of Commissioners was constituted, which recommended P15,000 per square meter, citing the valuation of similarly situated properties in the adjacent Hobart Village. The Republic opposed this, arguing the Board disregarded the property’s actual residential use, its physical condition, and the fact it had previously expropriated a portion of the same lot at a much lower rate.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s determination of just compensation at P15,000 per square meter.
RULING
The Supreme Court denied the petition and affirmed the assailed rulings. The Court emphasized that factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally binding and accorded great respect. It found no reason to deviate from these concurrent findings, as the petitioner failed to prove any error in the establishment of facts or the conclusions drawn therefrom. On the legal question, the Court ruled that the lower courts did not err in not strictly applying the valuation standards under Section 5 of Republic Act No. 8974 . The law states that courts “may consider” these standards to facilitate determination, with the word “may” being permissive and conferring discretion. The exercise of this discretion by the trial court, which accepted the commissioners’ report based on the comparable property in Hobart Village, was not shown to be tainted with grave abuse. Therefore, the affirmed amount of P15,000 per square meter stands as the valid just compensation.