GR 230144; (January, 2018) (Digest)
G.R. No. 230144 January 22, 2018
THE MANILA BANKING CORPORATION, Petitioner vs. BASES CONVERSION AND DEVELOPMENT AUTHORITY, Respondent
FACTS
Respondent Bases Conversion and Development Authority (BCDA), a government corporation, filed a complaint for expropriation against petitioner The Manila Banking Corporation (TMBC) and Bangko Sentral ng Pilipinas (BSP) to acquire a portion of land for the Subic-Clark-Tarlac Expressway (SCTEX) Project. BCDA initially offered a price based on the Bureau of Internal Revenue’s zonal valuation of ₱30 per square meter and deposited ₱5,590,650 with the court. The Regional Trial Court (RTC) issued a writ of possession, and BCDA took possession of the property. TMBC contested the offered price as grossly inadequate, arguing just compensation must reflect the property’s fair market value and account for consequential damages, including the severance of the remaining land.
The RTC, after trial, fixed just compensation at ₱500 per square meter. The Court of Appeals (CA) reversed this, setting compensation at ₱75 per square meter, which was BCDA’s final offer prior to filing. The CA held that the RTC erred in not considering the factors under Section 5 of Republic Act No. 8974 and in relying on TMBC’s valuation evidence, which pertained to a different, larger parcel. TMBC filed this petition, arguing the CA gravely erred in its determination of just compensation.
ISSUE
Whether the Court of Appeals erred in fixing the just compensation for the expropriated property at ₱75 per square meter.
RULING
Yes, the Supreme Court reinstated the RTC’s valuation of ₱500 per square meter. The Court emphasized that just compensation is the fair market value of the property at the time of taking, which is a judicial question. The CA incorrectly limited its review to the price offered during failed negotiations (₱75/sq.m.) and the zonal value (₱30/sq.m.). These are merely relevant factors, not conclusive proof of market value. The RTC’s determination was based on a commissioner’s report and substantial evidence, including ocular inspections, tax declarations, and sales data of comparable properties, which established the higher valuation. The Court found the RTC correctly considered the property’s nature, location, and potential use, as well as the consequential damages from the expropriation, such as the severance of the land. The CA’s substitution of its own judgment, without a clear showing that the RTC’s findings were baseless, constituted reversible error. Thus, the RTC’s factual findings, being supported by the record, are binding and reinstated.