NPC v. Bernal (G.R. No. 180979; December 15, 2010)


FACTS: NAPOCOR is a GOCC created by RA 6395, as amended, for the purpose of undertaking the development of hydroelectric power throughout the Philippines. To carry out the said purpose, NAPOCOR is authorized to exercise the power of eminent domain. Respondent Teresita Diato-Bernal is the registered owner of a parcel of land situated along General Aguinaldo Highway, Imus,Cavite. In order to complete the construction of structures and steel posts for NAPOCORs "Dasmaris-Zapote 230 KV Transmission Line Project," it had to acquire an easement of right of way over respondents property. Thus, NAPOCOR filed an expropriation suit against respondent, alleging, inter alia, that: the project is for public purpose; NAPOCOR negotiated with respondent for the price of the property, as prescribed by law, but the parties failed to reach an agreement. Respondent moved for the actions dismissal, arguing the impropriety of the intended expropriation, and claiming that the value of her property is more than what is being offered.On September 25, 1998, the parties filed with the RTC a partial compromise agreement which was approved by the RTC. Then the RTC proceeded to determine the amount of just compensation. Upon recommendation of appointed commissioners, the amount of PHP 10k per sq m based on the FMV was reported. NAPOCOR opposed the amount asserting that it was not substantiated by any official documents or registered deeds of sale of the subject properties neighboring lots. RTC issued an order adopting the recommendation. On appeal, the CA affirmed the RTCs decision.

ISSUE: Should  the resolution of the PAC-Cavite prevail over the valuation report of the court-appointed commissioners?

Just compensation is defined as the full and fair equivalent of the property taken from its owner by the expropriator. The measure is not the takers gain, but the owners loss. The word "just" is used to intensify the meaning of the word "compensation" and to convey thereby the idea that the equivalent to be rendered for the property to be taken shall be real, substantial, full, and ample. Indeed, the "just"-ness of the compensation can only be attained by using reliable and actual data as bases in fixing the value of the condemned property.

The trial court should have been more circumspect in its evaluation of just compensation due the property owner, considering that eminent domain cases involve the expenditure of public funds.

Hence, the legal basis for the determination of just compensation being insufficient, the ruling of the RTC and the affirming Decision and Resolution of the CA ought to be set aside.