GR L 13005; (October, 1917) (Digest)
March 8, 2026GR L 12963; (October, 1917) (Digest)
March 8, 2026G.R. No. and Date: G.R. No. L-12918, October 16, 1917
Case Title: THE MUNICIPALITY OF ANTIPOLO, plaintiff-appellee, vs. FRANCISCO DOMINGO, ET AL., defendants. FRANCISCO DOMINGO, appellant.
FACTS:
The Municipality of Antipolo initiated expropriation proceedings in the Court of First Instance of Rizal to acquire several parcels of land for public use. The defendants, including Francisco Domingo, answered by stating the value they claimed for their respective properties. Upon the parties’ request, the court appointed commissioners to assess the value of the lands. The commissioners submitted a report valuing Domingo’s land at P9,677. However, Judge Alberto Barretto, after reviewing the report and hearing the parties, found that the commissioners had proceeded on a wrong theory (basing value on rental value without sufficient proof) and reduced the valuation of Domingo’s property to P3,205.50. Francisco Domingo appealed this reduction, arguing that the court had no authority to modify the commissioners’ findings.
ISSUE:
Whether the trial court had the authority to modify the valuation of the expropriated property as determined by the commissioners.
RULING:
Yes, the trial court had the authority to modify the commissioners’ valuation. The Supreme Court affirmed the decision of the lower court, holding that courts may set aside the findings of commissioners in expropriation proceedings when such findings are based on a wrong theory or principle. The Court emphasized that it is the duty of the courts to ensure that neither the public is unjustly burdened by paying more than the property’s true value, nor the owner is prejudiced by receiving less. In this case, the commissioners’ valuation was based on rental value, but the record contained no proof of such rentals (in fact, Domingo alleged he had received no rents from the property for nine years). After examining the record, the Supreme Court found the lower court’s valuation to be approximately the true value of the property. The appellant’s procedural motion to strike the appellee’s brief was also denied as without merit. The judgment of the lower court was affirmed.
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