G.R. Nos. L-49291-92 and L-61237-39 October 29, 1987
Socorro M. Zaballero, et al. vs. National Housing Authority and The Court of Appeals; National Housing Authority vs. Socorro M. Zaballero, et al.

FACTS

The National Housing Authority (NHA) filed separate complaints in 1977 to expropriate several parcels of sugarcane land owned by the Zaballero family in Dasmariñas, Cavite, for a resettlement project. The NHA deposited amounts based on the tax-declared assessed values of the properties with the Philippine National Bank and obtained writs of possession. The landowners initially contested the expropriation but later conceded to it, subject to the determination of just compensation. Negotiations for the market value failed, leading to judicial proceedings.
During the trial, the Zaballeros presented evidence, including testimony and documents, to support a valuation of P9.50 per square meter. The NHA insisted that just compensation must be based solely on the assessor’s market value under the tax declarations, citing Presidential Decrees. The trial court fixed just compensation at P7.75 per square meter, which included a component termed “disturbance compensation” for crops and improvements. The Court of Appeals later nullified the trial court’s orders for provisional payment to the landowners, leading to these consolidated petitions.

ISSUE

The core issue is whether just compensation in expropriation proceedings is strictly limited to the assessor’s market value stated in tax declarations, as insisted by the NHA, or must be determined based on a judicial consideration of all relevant factors presented as evidence.

RULING

The Supreme Court ruled that just compensation must be determined judicially based on evidence, not confined to tax declarations. The Court affirmed the trial court’s valuation of P7.75 per square meter. The legal logic is anchored on the constitutional guarantee that private property shall not be taken for public use without just compensation. Just compensation means the full and fair equivalent of the property taken, payable at the time of taking.
The Court held that Presidential Decrees cited by the NHA, which pegged compensation to tax declaration values, could not restrict the court’s constitutional duty to determine just compensation independently. Such decrees are merely guidelines and cannot supplant judicial discretion. The trial court correctly considered various factors presented by the landowners, including the property’s classification, developmental costs, declared value, selling prices of similar lands, and consequential damages for crops and improvements. The amount labeled “disturbance compensation” was properly included as it represented consequential losses, a valid component of just compensation. Therefore, the Court of Appeals decision was set aside, and the trial court’s valuation was affirmed.