**Facts:**
The Republic of the Philippines, through the Department of Energy, sought the expropriation of two parcels of land in Mansilingan, Bacolod City, owned by Ropa Development Corporation, Robinson Yao, and Jovito Yao. The intent was to construct transmission towers for a geothermal project, requiring 32 square meters of land and an additional 288 square meters for a temporary easement right of way.
The owners contested, emphasizing the impact on the property, including fruit-bearing trees and the overall utility of the land due to the construction. Despite their opposition, the Regional Trial Court granted the Republic a writ of possession. The opposition then sought relief from the Court of Appeals, which initially halted the writ’s enforcement.
Parallelly, before the Court of Appeals’ decision, a Motion for Judgment on the Pleadings/Summary Judgment was filed by the landowners in the trial court. Upon resolution of the Court of Appeals petition, the trial court ruled in favor of the landowners, granting them just compensation for the land and temporary use, plus severance damages for the purported value reduction of the remaining land.
The Republic appealed, challenging the absence of commissioners’ appointment, the propriety of the judgment on the pleadings, and the compensation awarded for temporary land use. The Court of Appeals affirmed the trial court’s decision (except for the attorney’s fees). The Republic then elevated the matter to the Supreme Court.
**Issues:**
1. Is the appointment of commissioners mandatory in expropriation proceedings under Republic Act No. 8974?
2. Was the trial court correct in resolving the case through a judgment on the pleadings and/or summary judgment?
3. Are respondents entitled to compensation for the temporary use of the 288 square meter area?
**Court’s Decision:**
The Supreme Court granted the petition, setting aside the Court of Appeals’ decision. It held the appointment of commissioners as mandatory, citing the need for a detailed assessment of just compensation and consequential damages. The Court noted that resolving the case via judgment on the pleadings was improper due to the presence of genuine issues requiring evidentiary hearings. On the temporary use of land, the Court agreed with the petitioner, ruling that such temporary occupation does not constitute “taking” warranting full compensation, but rather, compensation akin to rental fees was more appropriate.
**Doctrine:**
The Supreme Court reiterates that in expropriation cases, especially under Republic Act No. 8974, the appointment of commissioners is mandatory for determining just compensation. This process is crucial for a thorough assessment and ensures due process. Furthermore, the judgment highlighted the distinction between permanent taking of property, which warrants just compensation, and temporary use, which may not necessarily entail full compensation but rather an evaluation of appropriate rental fees or damages.
**Class Notes:**
– Mandatory Appointment of Commissioners: In expropriation proceedings under Republic Act No. 8974, appointing commissioners to determine just compensation is not optional but a mandatory step for ensuring fair evaluation and due process.
– Just Compensation: Just compensation involves evaluating the property’s value at the time of taking, considering factors like the property’s conditions, its market value, and any consequential damages or benefits due to the expropriation.
– Temporary Use vs. Taking: Temporary use of property for public purposes does not equate to “taking” under the concept of eminent domain, requiring a different compensation approach, possibly akin to rental fees rather than full market value compensation for permanent taking.
**Historical Background:**
The case exemplifies the evolving legal standards and procedural requirements in Philippine expropriation law, particularly under Republic Act No. 8974. It clarifies the procedural interplay between this Act and the Rules of Court concerning the appointment of commissioners, underscoring the judiciary’s role in safeguarding property rights while facilitating state infrastructure projects.
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