G.R. No. L-15142; November 16, 1920
THE MANILA RAILROAD CO., plaintiff-appellant, vs. QUITERIA BUENCONSEJO, ET AL., defendants-appellees.

FACTS:
The Manila Railroad Company filed a complaint in the Court of First Instance of Albay to expropriate several parcels of land in Tabaco, Albay, necessary for the construction of its railway line from Legaspi to Tabaco. The company alleged it was unable to acquire the lands extrajudicially as some owners were unknown and others demanded excessive prices. The court authorized the company to take immediate possession upon depositing a sum with the Treasurer. Commissioners were appointed to assess the value of the lands and the corresponding indemnity. After hearings, the commissioners submitted their report. The trial court approved the report with modifications, reducing some valuations, and rendered judgment adjudicating the lands to the plaintiff upon payment of the fixed indemnities with legal interest. The plaintiff moved for a new trial, which was denied. The plaintiff appealed, assigning errors primarily concerning the court’s approval of the commissioners’ report and the valuation of the properties.

ISSUE:
1. Whether the trial court erred in approving the commissioners’ report without taking additional evidence and overruling the plaintiff’s objection.
2. Whether the trial court erred in the valuation of the expropriated properties, specifically in basing the assessment on hearsay evidence and sales that occurred years prior to the expropriation, and in not considering the benefits conferred by the railway construction.

RULING:
The Supreme Court affirmed the trial court’s judgment.

1. On the approval of the commissioners’ report: The Court held that the trial court did not err. Under Section 246 of the Code of Civil Procedure, the court has the discretion, after a hearing, to accept the commissioners’ report, recommit it, set it aside, or accept it in part. The trial court acted within its legal authority by accepting the report with slight modifications after hearing the parties.

2. On the valuation of the properties: The Court found no merit in the appellant’s arguments.
Regarding hearsay evidence: The Court found that the persons who had personal knowledge of the prior sales testified about the prices and circumstances. Their testimony was not hearsay and provided a proper basis for the commissioners’ comparison.
Regarding the age of the sales: While the sales used for comparison occurred years before the expropriation, the commissioners properly considered them only as a basis. They also took into account the increased commercial importance of Tabaco and the location of the lands relative to commercial activity, adjusting the valuation accordingly. This was consistent with jurisprudence (City of Manila vs. Estrada) which allows consideration of non-contemporaneous sales if changes in property values are accounted for.
* Regarding benefits from the railway: The Court noted that the appellant failed to point to any evidence in the record proving that the construction conferred special benefits on the landowners. In the absence of such proof, the commissioners correctly did not consider any offsetting benefits.

Finally, the Court emphasized that it is the duty of the appellant to point out specific evidence in the record to support its claims. Since the appellant failed to do so comprehensively, a detailed review of the evidence was not incumbent upon the Supreme Court. The judgment was affirmed with costs against the appellant.