G.R. No. 232120, September 30, 2020
NATIONAL GRID CORPORATION OF THE PHILIPPINES, PETITIONER, VS. CLARA C. BAUTISTA, MARRIED TO REY R. BAUTISTA, RESPONDENT.

FACTS

The National Grid Corporation of the Philippines (NGCP) filed a complaint for expropriation against Clara C. Bautista to acquire her 1,314-square meter property in Maramag, Bukidnon for a transmission line project. NGCP offered compensation based on the BIR zonal valuation of P10.00 per square meter. Bautista opposed, contending the property’s fair market value was higher, noting its actual use was residential and adjacent lots were industrial. The Regional Trial Court (RTC) appointed commissioners to determine just compensation. Two commissioners recommended P3,000.00 per square meter based on current sales and the property’s industrial character, while NGCP’s commissioner recommended only P25.00 per square meter, citing its agricultural classification per zoning.
The RTC rendered judgment, fixing just compensation at P600.00 per square meter. It found the lower valuations impractical and the higher valuation speculative, instead taking judicial notice of valuations in similar expropriation cases in the same locality. NGCP appealed to the Court of Appeals (CA).

ISSUE

The primary issue is whether the CA correctly dismissed NGCP’s appeal for failure to file an Appellant’s Brief within the reglementary period. A secondary issue, raised by NGCP, concerns the propriety of the RTC’s valuation of the expropriated property.

RULING

The Supreme Court denied the petition and affirmed the CA’s dismissal of the appeal. On procedural grounds, the Court held that the CA did not commit reversible error. Section 1(e), Rule 50 of the Rules of Court lists the failure to file the appellant’s brief as a ground for dismissal of the appeal. The CA’s dismissal was not a mere discretionary act but a proper application of the rules, as the records showed NGCP’s counsel received the notice to file brief. The Court found no compelling reason to relax the rules, emphasizing that procedural rules are not to be disregarded without justifiable cause.
On the substantive issue of just compensation, the Court found the RTC’s determination to be supported by evidence and in accordance with established principles. Just compensation is the full and fair equivalent of the property taken, considering its character, use, and market value. The RTC correctly relied on the commissioners’ reports and its own judicial notice of comparable cases, rather than relying solely on the outdated BIR zonal valuation or the restrictive zoning classification. The property’s actual use and character as “built-up” or industrial, as confirmed by ocular inspection, were valid considerations for a higher valuation. Therefore, the RTC’s award of P600.00 per square meter was neither confiscatory nor excessive.