G.R. No. 266921 , January 22, 2024
NATIONAL TRANSMISSION CORPORATION, PETITIONER, VS. SPOUSES LOUIS MARCO S. MANALO AND ROWENA MARIE T. MANALO, REPRESENTED BY FREDDIE M. ARGUELLES, AND NONYLON D. PEDRAJA AND NONNA D. PEDRAJA, REPRESENTED BY JULIANITO B. MONCAYO, RESPONDENTS.

FACTS

Respondents are the owners of parcels of land in Tanauan City, Batangas, traversed by a 500-KV transmission line constructed in 1998 by the National Power Corporation (NAPOCOR), petitioner TRANSCO’s predecessor. No expropriation proceedings were initiated at the time of taking. In 2020, respondents filed a Complaint for Inverse Condemnation before the Regional Trial Court (RTC), praying for the determination of just compensation pursuant to Republic Act (R.A.) No. 10752 (The Right-of-Way Act). Subsequently, respondents filed a Motion to require TRANSCO to make a provisional deposit under Section 6 of R.A. No. 10752 , equivalent to 100% of the current BIR zonal valuation of the affected properties.
TRANSCO opposed, arguing that R.A. No. 10752 applies only to new projects and not to existing transmission lines built long before its enactment. It contended that the provisional deposit, if any, should be based on the assessed value under Rule 67 of the Rules of Court, the rule in effect at the time of construction. The RTC granted respondents’ Motion and ordered the deposit based on zonal valuation. The Court of Appeals affirmed the RTC’s ruling, prompting TRANSCO to elevate the case via a Petition for Review on Certiorari.

ISSUE

Whether the determination of the provisional compensation/deposit in this inverse condemnation case is governed by R.A. No. 10752 or by Rule 67 of the Rules of Court.

RULING

The Supreme Court denied the petition and affirmed the assailed CA Decision. The Court held that R.A. No. 10752 governs the determination of provisional compensation in this case. The legal logic is anchored on the principle that the law in force at the time of the filing of the complaint for inverse condemnation controls both the procedural and substantive aspects of the compensation due. Since respondents initiated the inverse condemnation proceedings in 2020, after the effectivity of R.A. No. 10752 , its provisions apply.
The Court rejected TRANSCO’s argument that the law applicable at the time of the physical taking (1998) should govern. It cited the precedent in Felisa Agricultural Corporation v. National Transmission Corporation, which established that if the landowner initiates inverse condemnation proceedings after the effectivity of R.A. No. 8974 (the precursor to R.A. No. 10752 ), then said law shall apply. This rule ensures uniformity and fairness by applying the current statutory framework for compensation when the judicial determination of just compensation is sought. Consequently, Section 6 of R.A. No. 10752 , mandating a provisional deposit equivalent to 100% of the land’s value based on the current BIR zonal valuation, is controlling. The Court also deemed the specific valuation a factual matter, the findings on which by the lower courts are final and conclusive.