Meralco vs Pineda Case Digest

MERALCO VS PINEDA (1992) FACTS 

Petitioner is a domestic corporation duly organized and existing under Philippine Laws of the Philippines

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For the purpose of constructing a transmission line from Barrio Malaya to Pililia, Rizal, petitioner needed portions of land of the private respondents with an aggregate area of 237, 321 sqm; parties failed to reach an agreement despite despite negotiations and offers to pay compensation

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Petitioner then filed a complaint for eminent domain with the Court of First Instance of Rizal

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Court authorized petitioner to take and enter property sought to be expropriated

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Respondents filed for Motion for Withdrawal of deposit claiming they are entitled but were subsequently denied

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Petitioner then sold to NAPOCOR its power plants and transmission lines including the one in questions pursuant to a government policy

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The court then appointed commissioners for the appraisal of the land

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Commissioners’ work was suspended when petitioner filed a Motion to Dismiss because of their said sale to NAPOCOR

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Respondents filed another motion for payment and courts granted and another sum thereafter

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Petitioner then filed for a Motion for Reconsideration Reconsideration and alleged that “at this stage” the respondents are not yet entitled to payment of just compensation as there is no appraisal yet and that court, upon awarding a fraction of sum, based it only on a witness of a credible real estate broker instead of employing the assistance of three commissioners to determine just compensation

ISSUE 

Whether the court can dispense the employment of three commissioners in the ascertainment of just compensation

HELD 

No

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Rule 67 of the Revised Rules of Court provides: the court shall appoint 3 commissioners to ascertain just compensation and render judgment based on their reports

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2 stages of expropriation: expropriation: 1. Determination of the authority of the plaintiff to exercise power of eminent domain 2. Determination of the court of just compensation for the property sought done with the assistance of 3 commissioners commissioners

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A trial before commissioners in a mandatory and substantive right, indispensable indispensable to allow the parties to present evidence on the issue o f just compensation

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Reasons for court to disregard findings of commissioners: 1. Where the commissioners applied illegal principles to the evidence submitted to them 2. Where they have disregarded a clear preponderance of evidence 3. Where the amount is either grossly inadequate and excessive