G.R. No. L-73211. January 7, 1987.
NATIONAL POWER CORPORATION, petitioner, vs. THE INTERMEDIATE APPELLATE COURT, ALI DIMAL married to MACABANDO DIMAL, respondents.

FACTS

The National Power Corporation (NPC) initiated expropriation proceedings over a portion of a 46,431-square-meter parcel of land in Marawi City, owned by respondents Ali Dimal and Macabando Dimal. The land, registered under a Torrens Title originating from a government patent, was inundated due to the operation of NPC’s Agus Hydroelectric Plant project, rendering approximately 18,552 square meters virtually useless. In response to a claim for damages from the landowners, NPC opted to file for expropriation to determine just compensation.
The Regional Trial Court, upon evaluating the report of the appointed Commissioners, fixed the just compensation at Twelve Pesos (P12.00) per square meter. NPC appealed to the Intermediate Appellate Court (IAC), arguing this rate was excessive. NPC contended that the fair market value should be Three Pesos (P3.00) per square meter, aligning with the assessment made by the City Assessor of Marawi City, as referenced under P.D. 76, as amended. The IAC affirmed the trial court’s decision, prompting NPC to elevate the case to the Supreme Court via a Petition for Review.

ISSUE

Whether the Intermediate Appellate Court erred in affirming the trial court’s determination of just compensation at P12.00 per square meter, instead of adopting the P3.00 per square meter assessment by the City Assessor.

RULING

The Supreme Court ruled in favor of the respondents and affirmed the IAC’s decision. The legal logic centers on the constitutional and statutory requirement that just compensation must be the full and fair equivalent of the property taken, reflective of its true market value at the time of taking. The Court emphasized that the City Assessor’s earlier valuation of P3.00 per square meter was not conclusive. Notably, the same City Assessor, serving as a member of the Board of Commissioners tasked with determining just compensation in the expropriation proceedings, concurred with the recommended rate of P12.00 per square meter. This collective recommendation by the Commissioners, including the Assessor, effectively amended his prior assessment and represented a considered judicial determination of the property’s current and fair market value.
The Court found that compensating the landowners at only P3.00 per square meter would be unjust and inequitable, as it did not reflect the property’s true worth. The valuation of P12.00 per square meter was upheld as the legitimate just compensation, being the product of a proper commissioners’ report and subsequent judicial approval. The decision reinforces that assessor’s valuations are merely prima facie evidence and can be superseded by more current and comprehensive evidence presented in an expropriation proceeding to arrive at a fair and realistic market value.