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NATIONAL TRANSMISSION CORPORATION v. SPS. MARIANO S. TAGLAO

FACTS:

The National Transmission Corporation (TRANSCO) filed a Complaint for Eminent Domain against the spouses Mariano and Corazon Taglao (Spouses Taglao) to acquire an easement of right of way over a portion of their property for the construction of the Tayabas-Dasmariñas 500 KV Transmission Line Project. The RTC denied the Spouses Taglao's motion to dismiss and granted the NPC's motion for the issuance of a writ of possession over the subject portion of their property. The RTC subsequently declared the subject property as condemned. Commissioners were appointed to determine just compensation, with the NPC's recommended commissioner valuing the property at P156,690.44 and the commissioner for Spouses Taglao valuing it at P12,858,000. The RTC fixed the market value of the subject property at P1,000.00 per sq.m. and determined the just compensation at P509,170.00. The NPC's motion for reconsideration was denied by the RTC. The CA affirmed the RTC's ruling, and the NPC's motion for reconsideration was also denied by the CA. Thus, the NPC filed a Petition for Review on Certiorari before the Supreme Court.

ISSUES:

  1. Whether the determination of just compensation in an expropriation case should be based on the fair market value of the property at the time of taking or the filing of the complaint.

  2. Whether the valuation of the property made by the commissioners was based on the market value at the time of filing the complaint.

  3. Whether the valuation of the property made by the RTC and CA was arbitrary and unsupported by evidence.

  4. Whether the computation of just compensation by the Regional Trial Court (RTC) and the Court of Appeals (CA) is correct.

  5. Whether the National Power Corporation (NPC) should only pay 10% of the market value of the subject portion for the establishment of an easement of right of way.

RULING:

  1. Just compensation in an expropriation case should be based on the fair market value of the property at the time of taking or the filing of the complaint, whichever came first. In this case, since the complaint for eminent domain was filed before the taking, the fair market value should be determined based on the property's value at the time of filing the complaint.

  2. The valuations made by the commissioners were not based on the market value at the time of filing the complaint. The valuation recommended by the commissioner for the NPC was based on the market value stated on the property's tax declaration in 1993, while the valuation recommended by the commissioner for the Spouses Taglao was based on the market value in 2000.

  3. The valuations made by the RTC and CA were arbitrary and unsupported by evidence. The valuation of the RTC at P1,000 per sq.m. was not supported by any documentary evidence or explanation of how it was arrived at. The CA's justification for the valuation, based on the market value in 2000, was highly speculative and devoid of any actual and reliable basis.

  4. The computation of just compensation by the RTC and the CA is incorrect. The court held that the just compensation should not be limited to 10% of the market value of the subject property. The acquisition of an easement of right of way deprives the owner of the normal use of the property and, therefore, entitles the owner to payment of a just compensation, which must be the monetary equivalent of the land taken.

  5. The NPC is not required to pay only 10% of the market value of the subject portion for the establishment of an easement of right of way. The court ruled that the NPC is liable for the payment of a just compensation, which must be neither more nor less than the monetary equivalent of the subject property.

PRINCIPLES:

  • Just compensation in expropriation cases is the full and fair equivalent of the property taken, based on the fair market value at the time of taking or filing of the complaint, whichever came first.

  • Valuation of just compensation should consider factors such as the cost of acquisition, current value of like properties, size, shape, location, and tax declarations.

  • Valuation should be based on established rules, correct legal principles, and competent evidence. Speculation and surmises should be avoided.

  • The acquisition of an easement of right of way entitles the owner to payment of a just compensation, which must be the monetary equivalent of the land taken.

  • The limitations on the use of the property taken for an indefinite period would deprive its owner of the normal use thereof, necessitating just compensation.

  • The computation of just compensation should take into consideration the cost of acquisition of the land involved, the current value of like properties, its size, shape, location, as well as the tax declarations thereon, at the time of the filing of the complaint.