327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Is it just for the government to expropriate private land
at a valuation significantly lower than market value, especially when the land
is located in an area with escalating property prices?
G.R. No. 227960, July 24, 2019
Facts of the Case
The Republic of the Philippines, through the Department of
Public Works and Highways (DPWH), filed a complaint for expropriation against
an unknown landowner on November 23, 2007. The property in question was a
527-square-meter parcel of land in Barangay Ugong, Valenzuela City, intended
for the construction of the C-5 Northern Link Road Project. The government
initially sought to expropriate 413 square meters of the land, valuing it at
P3,450 per square meter based on the zonal valuation.
A court order for expropriation was issued on September 9,
2008, requiring the government to deposit P1,424,850 as 100% of the zonal
valuation for the property. The land was eventually identified as belonging to
Spouses Lorenzana Juan Darlucio and Cosme Darlucio, who contested the
valuation. They argued that the land should be appraised at P10,000 to P15,000
per square meter, given that it was industrially classified and located near
properties valued higher, particularly in Hobart Village, which had comparable
properties priced at P15,000 per square meter.
The trial court constituted a Board of Commissioners to
determine just compensation. The Board recommended the valuation of P15,000 per
square meter based on its assessment, which included referencing the Hobart
case where land in a nearby area had been expropriated at the same rate. The
Republic opposed this valuation, arguing that the Board failed to account for
the land’s actual classification, informal settlers, and the property's
condition.
The trial court, on May 16, 2014, ruled in favor of the
Spouses Darlucio, adopting the Board's recommendation and fixing the just
compensation at P15,000 per square meter. The court also ordered the Republic
to pay interest and consequential damages, including attorney's fees.
On appeal, the Court of Appeals (CA) modified the interest
rate and deleted the award of attorney's fees but affirmed the trial court’s
decision. The Republic elevated the case to the Supreme Court, contending that
the Hobart property should not dictate the valuation of the Darlucios' land,
and the zonal value should be considered more heavily in determining just
compensation.
Issue
Did the Court of Appeals commit an error in affirming the
amount of P15,000 per square meter as just compensation for the expropriated
land?
Ruling
The Supreme Court ruled against the Republic and affirmed
the decision of the Court of Appeals. The Court emphasized that in
expropriation cases, the determination of just compensation must be based on
the fair market value at the time of the taking. The Court further held that
the zonal valuation is only one of the factors in determining just compensation
and cannot be the sole determinant. The proximity of the expropriated property
to Hobart Village, where similar properties were valued at P15,000 per square
meter, was crucial in this case. The Republic's failure to refute the Board's
findings and present sufficient evidence to justify a lower valuation
significantly weakened its case.
Dispositive Portion
The Supreme Court dismissed the petition of the Republic of
the Philippines, affirming the Court of Appeals' ruling with modification. The
final judgment reiterated that the landowners are entitled to just compensation
at P15,000 per square meter, subject to adjustments in the interest rate from
12% to 6% per annum starting July 1, 2013, until full payment.
Is it fair for the government to rely on outdated zonal
valuations in cases of expropriation, especially when nearby properties reflect
a much higher market value?
Important Doctrines:
- Just
Compensation Standard: "The measure is not the taker’s gain but
the owner’s loss." Just compensation is meant to be full,
substantial, and reflective of the property's market value at the time of
taking.
- Multiple
Factors in Valuation: Section 5 of Republic Act No. 8974 specifies
that courts may consider factors like the property’s classification,
developmental costs, and selling price of similar lands when determining
just compensation.
- Judicial
Discretion in Expropriation: Courts are not bound by zonal valuations
alone; they must exercise discretion and consider other evidence,
including comparable market prices of similarly situated properties.
Classification: Civil Law (Expropriation)
🎓 This CONTENT will
explore a landmark jurisprudence on just compensation in land expropriation,
aimed to assist law students and Bar examinees in understanding and
recalling critical legal doctrines from a Supreme Court decision.
We will break down the case of Republic of thePhilippines (through the Department of Public Works and Highways) vs. SpousesLorenzana Juan Darlucio and Cosme Darlucio, G.R. No. 227960, promulgated onJuly 24, 2019, a Civil Law case involving expropriation and just
compensation.
The main issue in the case was:
Should the government be allowed to determine
compensation solely based on outdated zonal valuation despite higher nearby
property market prices?
The Supreme Court upheld the P15,000 per square meter
valuation determined by the trial and appellate courts, rejecting the
government’s reliance on outdated zonal values and affirming the constitutional
mandate of full and fair compensation.
👉 Should landowners bear
the financial loss when government valuations lag behind actual market value?
🔍 10 DOCTRINES FROM THE
CASE (Cited from Supreme Court Decision in G.R. No. 227960)
- Just
Compensation Defined
“Just compensation” means the full and fair equivalent of the property taken, not merely what the expropriator is willing to pay. (G.R. No. 227960, citing Oroville Development) - Owner’s
Loss, Not Taker’s Gain
The proper measure is the owner’s loss, not the taker’s gain, ensuring a balanced and fair compensation standard. (G.R. No. 227960) - Time
of Taking Is Determinative
Valuation must be based on the property's value at the time of taking, not at the time of litigation or earlier expropriations. (G.R. No. 227960) - Zonal
Valuation Is Not Conclusive
Zonal valuation is only one factor; it cannot solely determine just compensation. Courts must exercise discretion. (G.R. No. 227960, citing RA 8974) - Judicial
Function in Valuation
Courts must independently evaluate just compensation; they are not bound by administrative valuations like BIR zonal rates. (G.R. No. 227960) - Comparable
Sales in Vicinity
Sales or valuation of similar lands nearby (e.g., Hobart Village) are relevant benchmarks in determining fair value. (G.R. No. 227960) - Presence
of Informal Settlers Must Be Proven
Allegations of decreased property value due to squatters must be backed by concrete evidence, not speculation. (G.R. No. 227960) - Board
of Commissioners’ Report Holds Weight
Courts give great respect to valuation findings of the Board of Commissioners unless proven arbitrary or unsupported. (G.R. No. 227960) - Interest
on Just Compensation
If payment is delayed, legal interest applies from the time of taking until full payment to preserve the value of compensation. (G.R. No. 227960) - Judicial
Discretion Under RA 8974
Section 5 of RA 8974 lists standards the court may consider, underscoring judicial discretion—not mandatory application. (G.R. No. 227960)
📚 FAQs
1. What is the main issue in this case?
Whether the government can rely solely on zonal valuation in
expropriation when nearby property values are significantly higher.
2. Why was P15,000/sq.m. upheld as just compensation?
Because it reflected the fair market value of
comparable properties in the same area, specifically Hobart Village.
3. What is RA 8974?
A law providing the framework for determining just
compensation in national infrastructure projects. Courts may consider listed
standards under Section 5.
4. Can the Supreme Court change factual findings of lower
courts in Rule 45 petitions?
Generally no, unless there’s grave abuse of discretion
or serious misapprehension of facts. This was not found in the case.
5. Is this decision binding for similar cases?
Yes, it serves as a precedent, particularly for
expropriation cases involving similar factual and geographic conditions.
📌 Disclaimer:
This is an educational video made using premium AI tools.
It is not legal advice, and no guarantee of infallibility is
made. Viewers must consult legal professionals for case-specific concerns.
🎥 Like, save, and
comment:
Should landowners always be entitled to market value—even
when the government claims it’s unaffordable?
🎓 Welcome to this short
quizzer on a landmark Supreme Court decision in Civil Law, focusing on expropriation
and just compensation. This quiz is based on the case:
Republic of the Philippines (through the Department of
Public Works and Highways) v. Spouses Lorenzana Juan Darlucio and Cosme
Darlucio,
G.R. No. 227960, promulgated on July 24, 2019.
In this case, the government offered to expropriate private
property at ₱3,450 per square meter, while the owners asserted it was
worth ₱15,000, based on nearby comparable properties. The Supreme
Court sided with the owners, affirming the valuation approved by the lower
courts and rejecting the government's reliance on outdated zonal values. The
Court upheld the doctrine that just compensation must reflect the owner’s
actual loss, not the taker’s convenience.
📌 The Answer Key
will be provided at the end of the video. Let's begin.
✅ HOTS MULTIPLE CHOICE QUESTIONS
(Easy Difficulty)
1. What was the primary legal issue in the case between
the Republic and the Spouses Darlucio?
A. Ownership of land
B. Validity of land title
C. Fair determination of just compensation
D. Zoning classification of the property
2. What factor did the Supreme Court emphasize as the
proper measure for just compensation?
A. Government valuation
B. Tax declaration value
C. Taker’s gain
D. Owner’s loss
3. Which type of land classification was used to
value the expropriated property in the case?
A. Agricultural
B. Residential
C. Commercial
D. Industrial
4. Why did the Court reject the government’s reliance
on the previously paid value of ₱2,000 per square meter for the same property
in 1997?
A. It was not supported by title
B. It was based on informal estimates
C. It was no longer reflective of market value at the time
of taking
D. The land had been transferred to new owners
5. What did the Court say about the use of zonal
valuation as the basis for compensation?
A. It is mandatory and conclusive
B. It is the only valid standard
C. It is one of many factors to consider
D. It overrides judicial findings
6. The valuation of ₱15,000 per square meter was
based primarily on which comparison?
A. Tax records in other cities
B. Satellite imaging of the area
C. Final valuation in a nearby expropriation case
D. Internet listings for nearby lots
7. Which body conducted the initial recommendation of
just compensation in the trial court?
A. Register of Deeds
B. Department of Finance
C. Board of Commissioners
D. Zoning Authority
8. What was the Supreme Court's stance on factual
findings by the trial and appellate courts?
A. Subject to automatic review
B. Presumed incorrect unless re-evaluated
C. Generally binding and respected
D. Overruled unless based on the law
9. What interest rate was applied to the unpaid
balance of just compensation after July 1, 2013?
A. 2%
B. 6%
C. 10%
D. 12%
10. What did the Supreme Court say about the presence
of informal settlers affecting land value?
A. Always lowers land value
B. Must be presumed in urban areas
C. Must be proven with clear evidence
D. Has no legal relevance to valuation
Let me know when you're ready to reveal the Answer Key!
From <https://chatgpt.com/c/66f01cc4-87b0-800a-a6e1-dde350866b90>
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