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NAPOCOR v. ILETO

The National Power Corporation filed a complaint to expropriate land in Bulacan for a transmission line project. While NPC claimed it only acquired an aerial easement, the court allowed it to possess the land and ordered it to pay just compensation to the landowners, deducting any unpaid taxes. On appeal, the Supreme Court ruled that determining just compensation is a judicial function, and courts are not bound by statutory valuations - courts have discretion to determine the proper compensation based on their own judgment.

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203 views

NAPOCOR v. ILETO

The National Power Corporation filed a complaint to expropriate land in Bulacan for a transmission line project. While NPC claimed it only acquired an aerial easement, the court allowed it to possess the land and ordered it to pay just compensation to the landowners, deducting any unpaid taxes. On appeal, the Supreme Court ruled that determining just compensation is a judicial function, and courts are not bound by statutory valuations - courts have discretion to determine the proper compensation based on their own judgment.

Uploaded by

Jen Dee
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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NAPOCOR v.

ILETO
G.R. No. 169957 & 171558, July 11, 2012, Second Division (Brion, J.)

FACTS:
On October 7, 1997, the National Power Corporation (NPC) filed a complaint,
which was subsequently amended, seeking to expropriate certain parcels of land in
Bulacan, in connection with its Northwestern Luzon Transmission Line project. As a
consequence, the Court hereby allows the National Power Corporation to remain in
possession of the aforementioned areas which it had entered on December 16,
1997 and further orders it to pay the respective owners thereof the following just
compensation, with legal interest from the taking of possession (Sec. 10, Rule 67 of
[the] 1997 Rules of Civil Procedure), and after deducting the sums due the
Government for unpaid real estate taxes and other charges.
ISSUE:
Whether or not the trial court erred in fixing the amount of just compensation
purportedly for the acquisition of the property despite the fact that the NPC
acquired only an aerial easement of right of way over the agricultural lands of
respondents
RULING:
The determination of just compensation in expropriation cases is a function a
ddressed to thediscretion of the courts, and may not be usurped by any other
branch or official of the government. We already established in Export Processing
Zone Authority v. Dulay, 149 SCRA 305 (1987), that any valuation for
just compensation laid down in the statutes may serve only as guiding principle or
one of the factors in determining just compensation, but it may not substitute the
courts’ own judgment as to what amount should be awarded and how to arrive at
such amount. We said: The determination of “just compensation” in eminent
domain cases is a judicial function. The executive department or the legislature may
make the initial determinations[,] but when a party claims a violation of the
guarantee in the Bill of Rights that private property may not be taken for public use
without just compensation, no statute, decree, or executive order can mandate that
its own determination shall prevail over the court’s findings. Much less can the
courts be precluded from looking into the “justness” of the decreed compensation.

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