Sunday, February 19, 2017

G.R. No. 165828 NPC v. HEIRS OF SANGKAY 656 SCRA 60

NPC v. HEIRS OF SANGKAY
656 SCRA 60
G.R. No. 165828
August 24, 2011

TOPIC: Eminent Domain; Just Compensation

FACTS: National Power Corporation (NPC) undertook the Agus River Hydroelectric Power Plant Project to generate electricity for Mindanao. It included the construction of several underground tunnels to be used in diverting the water flow from the Agus River to the hydroelectric plants.

On 1997, Respondents sued NPC for recovery of damages of the property and a prayer for just compensation. They alleged that the tunnel deprived them of the agricultural, commercial, industrial and residential value of their land; and that their land had also become an unsafe place for habitation, forcing them and their workers to relocate to safer grounds.

ISSUE: Whether the Heirs of Sangkay have the right to just compensation

RULING: Just compensation is the full and fair equivalent of the property taken from its owner by the expropriator. It has the objective to recover the value of property taken in fact by the governmental defendant, even though no formal exercise of the power of eminent domain has been attempted by the taking agency.

The underground tunnels impose limitations on respondents’ use of the property for an indefinite period and deprive them of its ordinary use. Hence, respondents are clearly entitled to the payment of just compensation.

Notwithstanding the fact that petitioner only occupies the sub-terrain portion, it is liable to pay not merely an easement fee but rather the full compensation for land. It is settled that the taking of private property for public use, to be compensable, need not be an actual physical taking or appropriation. This is so because in this case, the nature of the easement practically deprives the owners of its normal beneficial use. Compensable taking includes destruction, restriction, diminution, or interruption of the rights of ownership or of the common and necessary use and enjoyment of the property in a lawful manner, lessening or destroying its value




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