THE CITY OF MANILA, plaintiff-appellant, vs. BALBINA ESTRADA Y SARMIENTO, minor and only heiress of Concepcion Sarmiento, deceased, and ARISTON ESTRADA, personally, and as administrator, defendants-appellants.
FACTS
The City of Manila filed an expropriation case to acquire a parcel of land with improvements in Paco for a new market. Commissioners were appointed, but they submitted conflicting reports on the land’s value. The trial court, in its decision, fixed the just compensation at P15 per square meter, modifying the commissioners’ majority report which recommended P20 per square meter. Both parties appealed this valuation. The Supreme Court, after reviewing the evidence, initially rendered a short decision fixing the compensation at P10 per square meter, and subsequently issued this extended opinion to explain its reasons.
ISSUE
What is the just compensation for the land being expropriated?
RULING
The Supreme Court affirmed its earlier ruling that P10 per square meter is the just compensation. The Court based its decision on two grounds: first, the great preponderance of evidence supported this valuation, and second, the court possesses the power to revise the commissioners’ report when the award is grossly excessive or inadequate. The evidence showed that comparable land across the estero sold for P6 per square meter shortly before the hearings. The City’s tax appraisal of the subject land was P6 per square meter. The Court found the defendants’ reliance on a prior expropriation (the Clarke transaction, which resulted in an effective price of P19.85 per square meter due to consequential damages) to be an unreliable standard for the market value of the subject property. The Court held that the trial court’s award of P15 was excessive and not supported by the evidence of actual market value.
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