GR 243900; (October, 2021) (Digest)
G.R. No. 243900. October 06, 2021
REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE DEPARTMENT OF PUBLIC WORKS AND HIGHWAYS, PETITIONER, VS. EDESIO T. FRIAS, SR., RESPONDENT.
FACTS
The Republic, through the DPWH, instituted a case for the expropriation of a 468 sq. m. parcel of land owned by respondent Edesio T. Frias, Sr. in Butuan City for the Cotabato-Agusan River Basin Development Project. The RTC issued an Order of Expropriation and a Writ of Possession after the Republic deposited the assessed value of P81,900.00. The parties initially agreed to enter into a compromise agreement on just compensation, leading to multiple postponements granted at the Republic’s behest. After several years with no agreement reached, and upon manifestation by Frias’ counsel without objection from the Republic’s counsel, the RTC dispensed with the appointment of a Board of Commissioners. The parties submitted position papers. The Republic based its valuation on the Tax Declaration (P90.00 per sq. m.) and BIR Zonal Valuation (P263.14 per sq. m.). Frias submitted a Deed of Absolute Sale between the Republic and another landowner for a similarly situated property in Baan Riverside, also used for the DPWH project, to support his claim of P980.00 per sq. m. The RTC set just compensation at P737.83 per sq. m., based on the market value indicated in said Deed. The CA affirmed the RTC decision. The Republic filed this petition, arguing denial of due process due to the non-constitution of a Board of Commissioners and error in the determination of just compensation.
ISSUE
1. Whether the Court of Appeals committed an error in ruling that petitioner’s right to due process was not violated.
2. Whether the Court of Appeals committed an error in affirming the amount of just compensation determined by the trial court.
RULING
The Supreme Court DENIED the petition and AFFIRMED the assailed CA Decision and Resolution.
1. On due process: The Republic was not denied due process. The essence of procedural due process is notice and an opportunity to be heard, which can be through pleadings. The Republic was given every reasonable opportunity to present its case. It did not object to the motion to dispense with the Board of Commissioners, agreed to enter into a compromise, and was granted multiple postponements. It submitted its position paper and evidence. Its failure to scrutinize or object to Frias’ documentary evidence for over nine months before the RTC rendered its decision negates its claim of deprivation.
2. On just compensation: The RTC did not err in determining just compensation at P737.83 per sq. m. based on the Deed of Absolute Sale for a similar property. The trial court has discretion to determine just compensation based on competent evidence, and it may consider the price of similar land in the vicinity as an indication of market value. The Republic failed to present clear and convincing evidence that the valuation was exorbitant or unjustified. The award of legal interest at 12% per annum from December 14, 2005 until June 30, 2013, and 6% per annum from July 1, 2013 until full payment, was also upheld.