FACTS:
On June 1, 1999, the National Power Corporation (NAPOCOR) filed an expropriation complaint against Marinduque Mining and Industrial Corporation and Industrial Enterprises, Inc. (petitioners) for the AGUS VI Kauswagan 69 KV Transmission Line Project. NAPOCOR sought to expropriate 7,875 square meters of the petitioners' property. In response, petitioners argued that the expropriation should cover the entire parcel of land, as it would render the remaining portion valueless and unfit for any purpose.
The trial court determined the fair market value of the 7,875-square meter lot at P115 per square meter and ordered the commissioners to determine the fair market value of the "dangling area" which consisted of 58,484 square meters affected by NAPOCOR's transmission lines.
NAPOCOR's motion for reconsideration was denied by the trial court. The trial court then declared that the "dangling area" consisted of 48,848.87 square meters and fixed its fair market value at P65 per square meter. The trial court also ruled that petitioners were entitled to consequential damages as NAPOCOR's expropriation impaired the value of the "dangling area" and deprived petitioners of the ordinary use of their property.
Another motion for reconsideration filed by NAPOCOR was denied by the trial court. Petitioners then moved for the execution of the trial court's decisions, which the trial court partially granted and issued a writ of execution.
Petitioners filed a motion to strike out or declare as not filed NAPOCOR's notice of appeal dated April 2, 2002, arguing that NAPOCOR violated the Rules of Court by filing and serving the notice via registered mail instead of personally. The trial court granted petitioners' motion and declared its Supplemental Decision final and executory.
NAPOCOR filed a motion for reconsideration which was denied by the trial court. They then filed a special civil action for certiorari before the Court of Appeals, seeking to reverse the trial court's denial of their notice of appeal. The Court of Appeals ruled in favor of NAPOCOR, set aside the trial court's orders, and directed the trial court to give due course to NAPOCOR's appeal. The Court of Appeals maintained that the notice of appeal should not have been denied considering the substantial amount of public funds involved and the significant disparity between the area sought to be expropriated and the "dangling area."
ISSUES:
- Whether the trial court erred in denying NAPOCOR's notice of appeal on the ground that it was not filed and served personally.
RULING:
- The Court of Appeals ruled in NAPOCOR's favor and set aside the trial court's denial of the notice of appeal. The Court of Appeals declared that the trial court acted whimsically and capriciously in denying the notice of appeal and declared the decision final and executory. The Court of Appeals emphasized that the Rules of Court should be liberally construed to effect substantial justice.