**Manila Electric Company (MERALCO) vs. The Honorable Gregorio G. Pineda, et al.**
### Facts:
Manila Electric Company (MERALCO), a domestic corporation, initiated a complaint for eminent domain against 42 defendants, including Teofilo Arayon, Sr., Gil de Guzman, Lucito Santiago, and Teresa Bautista. The plaintiffs sought to expropriate approximately 237,321 square meters of land for constructing a 230 KV Transmission line. Negotiations for compensation with the landowners failed, leading to various legal motions, including motions to dismiss based on claims that MERALCO’s corporate existence had expired and that the area requested was excessive. Despite opposition, the Court of First Instance authorized MERALCO to take possession of the property. Subsequent motions by the respondents for withdrawal of deposits for compensation resulted in court orders allowing partial withdrawals before a complete valuation was done. MERALCO’s motion to dismiss the complaint, due to the sale of its interests to the National Power Corporation (Napocor), was denied by the court. The court then appointed a Board of Commissioners for appraisal but proceeded to determine compensation without their report, leading to MERALCO’s petition for review on the claim of due process violation.
### Issues:
1. Whether the respondent court violated MERALCO’s constitutional right to due process by determining just compensation without formal evidence presentation and assistance from a Board of Commissioners.
2. Whether the National Power Corporation should be impleaded in substitution or in addition to MERALCO as a party plaintiff.
### Court’s Decision:
The Supreme Court granted MERALCO’s petition, nullifying the lower court’s orders that determined just compensation without a Board of Commissioners’ assistance. It held that determining just compensation in expropriation proceedings without formal evidence reception and without the aid of commissioners constituted a flagrant violation of due process. The Supreme Court emphasized the necessity of a Board of Commissioners in ascertaining just compensation and allowed the withdrawal of deposits by property owners pending a final valuation. Furthermore, it recognized that Napocor, having acquired interests from MERALCO, should either be impleaded in substitution of MERALCO or added as a party plaintiff. Consequently, the case was remanded for trial with instructions to implead Napocor accordingly.
### Doctrine:
In expropriation proceedings, determining just compensation without the assistance of a Board of Commissioners and without proper evidence constitutes a violation of the constitutional right to due process. The assistance of a Board of Commissioners is mandatory for accurately ascertaining just compensation for expropriated property.
### Class Notes:
– Eminent Domain: The government or its authorized entities’ right to expropriate private property for public use, with fair compensation.
– Just Compensation: The fair value to be paid for expropriated property, determined as of the date of filing of the complaint.
– Due Process: Legal requirement that ensures fair treatment through the normal judicial system, especially as a citizen’s entitlement.
– Board of Commissioners: A body mandated by law, specifically in expropriation proceedings, to assist in determining just compensation for expropriated property.
**Key Statutes and Provisions:**
– Right to Due Process: Protected under the Constitution, ensuring fair legal procedures.
– Rule 67 of the Revised Rules of Court: Governs expropriation proceedings, particularly Sections 5 and 8 regarding the appointment of commissioners and court actions on their report.
### Historical Background:
Expropriation cases in the Philippines involve a two-stage process, focusing initially on the right and propriety of expropriation and subsequently on determining just compensation. This case underscores the procedural safeguards in determining just compensation, highlighting the balance between public necessity and individual property rights.
Leave a Reply