GR L 3526; (March, 1952) (Digest)
G.R. No. L-3526 March 27, 1952
Republic of the Philippines, plaintiff-appellee, vs. Segunda L. Garcia, et al., defendants-appellants.
FACTS
The plaintiff-appellee, Republic of the Philippines, instituted condemnation proceedings to expropriate a 240,064-square-meter tract of land owned by the estate of William C. Hart, with defendant-appellant Segunda L. Garcia as the judicial administratrix and devisee. The expropriation was for the expansion of Clark Field Air Base, a United States military establishment, pursuant to the Military Bases Agreement. Three commissioners were appointed to ascertain compensation. The majority report classified 22.5 hectares as agricultural land valued at P1,000 per hectare and 1.5 hectares as residential land valued at P1 per square meter, plus P900 for destroyed trees. A dissenting commissioner believed the entire property was agricultural and valued it at P900 per hectare. The trial court concurred with the dissent’s classification (entirely agricultural) but fixed the value at P1,000 per hectare. The appellants contested the classification and valuation, arguing that a larger portion (four hectares) was residential and should be compensated as such, and that higher valuations from other condemnation proceedings and sales in the same locality should be considered.
ISSUE
The primary issues are: (1) Whether a portion of the expropriated land should be classified as residential, and if so, its area; (2) Whether the valuation fixed by the trial court for the agricultural land is correct; and (3) Whether evidence of other condemnation decisions and sales involving nearby properties, presented for the first time on appeal, can be considered in determining just compensation.
RULING
The Supreme Court modified the trial court’s decision. It held: (1) The four-hectare portion (40,000 square meters) of the property, designated as “A-2,” was entirely residential based on pre-war use and potential. The Court found that this area was part of the former Barrio Margot, where Hart had business establishments and houses before their wartime destruction, and it was suited for residential and business purposes. The absence of houses at the time of taking was not decisive. The principle of estoppel did not bar this finding, as the adverse party was not misled by a prior inconsistent statement from the appellant’s counsel. This portion was valued at P1 per square meter, as assessed by the majority commissioners. (2) The classification of the remaining 200,064 square meters as third-class agricultural land and its valuation at P1,000 per hectare were affirmed, as not shown to be erroneous by the evidence on record. (3) The other condemnation decisions and sales (e.g., involving McCrann and Valdez properties) could not be considered on appeal because they were not presented as evidence before the commissioners or the trial court. The report of commissioners is accorded great respect, and new evidence cannot be introduced at the appellate stage without remand for a new trial, which was not effectively pursued. The appellant was awarded compensation accordingly, plus legal interest if rent was not paid or covenanted, and costs.
