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NATIONAL POWER CORPORATION v. SANTA LORO VDA. DE CAPIN

FACTS:

The case involves the expropriation of parcels of land by the National Power Corporation (NAPOCOR) for its Interconnection Project. The affected landowners, including the respondents, initially gave permission for NAPOCOR to enter their properties, believing they would be justly compensated. However, after completing the construction, NAPOCOR imposed restrictions on the use of the lands and paid the respondents a smaller sum compared to other landowners in the area. The respondents filed a complaint seeking rescission of the agreement, recovery of possession, damages, and other reliefs, which was granted by the RTC. The only issue for resolution was the determination of just compensation.

The RTC ordered NAPOCOR to file its Comment on the respondents' Motion for Summary Judgment. NAPOCOR requested an extension but failed to file its Comment within the extended period, leading the court to deem the Motion for Summary Judgment submitted. The RTC rendered a Resolution in favor of the respondents, ordering NAPOCOR to pay damages for the portion of land taken, with interest at 14% per annum computed since 1996. NAPOCOR filed a Motion for Reconsideration, which was partially granted by the RTC, reducing the interest rate.

NAPOCOR appealed to the Court of Appeals, but its appeal was denied, leading it to file a Petition before the Supreme Court. NAPOCOR argued that the RTC erred in using summary judgment to resolve the case instead of appointing commissioners to ascertain just compensation. NAPOCOR also challenged the fair market value fixed by the RTC and disputed the legal and factual bases for the damages awarded to the respondents. NAPOCOR claimed that it only acquired an easement right of way but was still liable to pay an easement fee based on the fair market value of the affected portions of the properties.

The Supreme Court explained the concept of summary judgment as a procedural technique to eliminate sham claims or defenses early in the litigation process. The court clarified the requisites for summary judgment to be proper and found NAPOCOR's arguments without merit.

ISSUES:

  1. Whether the petitioner can raise any issue as to any material fact in the case.

  2. Whether the complaint of the respondents is for "reversed eminent domain" or damages.

  3. Whether the provisions of the Rules of Court on the ascertainment of just compensation are applicable.

  4. Whether the petitioner violated the respondents' right to just compensation.

  5. Whether the RTC can award just compensation to the respondents based on a previous decision in another case.

  6. Whether the just compensation awarded for the property in Civil Case No. DNA-379 can be used as a basis for determining the just compensation due in Civil Case No. DNA-547.

  7. Whether the petitioner only acquired an easement of right of way on the properties of the respondents and is liable to pay an easement fee.

  8. Whether the acquisition of an easement of right of way on the lands of the respondents constitutes expropriation and entitles the respondents to just compensation.

  9. Does Section 3A of the petitioner's charter violate the constitutional requirement of just compensation?

  10. Can the market value stated in the tax declaration of the expropriated property be considered as the fair and full equivalent to the loss sustained by the property owner?

RULING:

  1. The petitioner cannot raise any issue as to any material fact in the case since it remained silent when the motion for summary judgment was filed with the RTC. The court found the petitioner's actuation to be a dilatory tactic in the payment of just compensation, and therefore the RTC was justified in resorting to summary judgment.

  2. The complaint of the respondents is not for "reversed eminent domain" but for damages. The proceedings before the RTC were not for expropriation, but for damages to which the provisions of Rule 67 of the Revised Rules of Court are irrelevant.

  3. The provisions of the Rules of Court on the ascertainment of just compensation are not applicable since the case is no longer an action for expropriation. The case has been reduced to a simple case of recovery of damages, making the trial before commissioners dispensable.

  4. The petitioner violated the respondents' right to just compensation by paying them negligible amounts as easement fees instead of the fair market value of their affected properties. Other landowners who resisted the taking of their properties were paid just compensation, making it unjust for the respondents to receive lesser values as easement fees.

  5. The RTC can award just compensation to the respondents based on a previous decision in another case where the RTC ordered the petitioner to pay just compensation to the heirs of Tomas Gingco for their affected property. The lots owned by the heirs of Tomas Gingco and the respondents are located within the same area and separated only by another lot.

  6. The just compensation awarded for the property in Civil Case No. DNA-379 can be used as a basis for determining the just compensation due in Civil Case No. DNA-547 because the personalities and properties in both cases were essentially in similar situations.

  7. The petitioner cannot insist that it only acquired an easement of right of way on the properties of the respondents and is liable to pay an easement fee. The acquisition of an easement of right of way constitutes expropriation and entitles the respondents to just compensation.

  8. The acquisition of an easement of right of way on the lands of the respondents constitutes expropriation and entitles the respondents to a reasonable and just compensation.

  9. Section 3A of the petitioner's charter is found to be in violation of the constitutional requirement of just compensation. The Charter's provision, which obliges the petitioner to pay only a maximum of 10% of the market value declared in the tax documents, would render useless the protection guaranteed by the Constitution that no private property should be taken for public use without just compensation.

  10. The market value stated in the tax declaration of the expropriated property cannot be considered as the fair and full equivalent to the loss sustained by the property owner. It is violative of due process to deny the property owner the opportunity to contest the fairness or accuracy of the valuation in the tax documents. It is also unjust to allow the valuation made by a minor bureaucrat or clerk to absolutely prevail over the judgment of a court, which considers various factors and evaluations in determining just compensation.

PRINCIPLES:

  • For a summary judgment to be proper, there must be no genuine issue as to any material fact, except for the amount of damages, and the party presenting the motion for summary judgment must be entitled to a judgment as a matter of law.

  • A "genuine issue" is an issue of fact which requires the presentation of evidence and is distinguished from a sham, fictitious, contrived, or false claim.

  • Trial courts may render summary judgments only when there is clearly no genuine issue as to any material fact. When the facts as pleaded by the parties are disputed or contested, summary judgment cannot take the place of trial.

  • Silence or inaction of a party may be construed as a dilatory tactic and justify the court's resort to summary judgment.

  • The determination of just compensation is not applicable in cases where the proceedings are for damages and not expropriation.

  • Procedural laws cannot protect a party who has arbitrarily violated another party's right to just compensation.

  • Voluntarily dealing with a petitioner does not justify receiving lesser values as easement fees compared to other resisting landowners.

  • Previous decisions in related cases can be considered in determining just compensation in subsequent cases.

  • Just compensation is the full and fair equivalent of the property taken from its owner by the expropriator and is based on the owner's loss, not the taker's gain.

  • The acquisition of a right-of-way easement falls within the power of eminent domain and can result in the imposition of a burden on the owner of the condemned property without loss of title and possession.

  • Real property may be subjected to an easement of right-of-way through expropriation.

  • The payment of just compensation is a constitutional requirement when private property is taken for public use.

  • The valuation of a property stated in the tax declaration is not an absolute substitute for just compensation.

  • It is a violation of due process to deny the property owner the opportunity to challenge the valuation in the tax documents.

  • The judgment of a court, which considers expert commissioners' assessment and takes into account all relevant factors, should prevail over the valuation made by a minor bureaucrat or clerk.