NATIONAL POWER CORPORATION

v.
SPOUSES RODOLFO ZABALA

G.R. No. 173520 January 30, 2013

Anthony Adrian T. Perez

 Legislative enactments, as well as executive
issuances, fixing or providing fix the method of
computing just compensation are tantamount to
impermissible encroachment on judicial
prerogatives. Thus they are not binding on courts
and, at best, are treated as mere guidelines in
ascertaining the amount of just compensation
 FACTS
National Power Corporation (NAPOCOR) filed a complaint
for Eminent Domain defendant spouses, before the RTC,
alleging that defendants own parcels of land that it
urgently needed an easement of right of way for its
transmission lines and that the said parcels of land have
neither been applied nor expropriated for any public use,
and were selected in a manner compatible with the
greatest public good and the least private injury. The
defendant spouses moved to dismiss the complaint
averring that the traversing of the transmission lines
through their property would impact negatively on the
housing expansion in city, that the high tension wires
would endanger the life and limb of the inhabitants within
the area, and decrease the value of their subject property.
 FACTS
Thus, it shows that the installation of the proposed
transmission wires on their property was not the most
direct, practical and least burdensome means to achieve
public good. Thereafter, the Commissioners submitted
their Final Report/Recommendation fixing the just
compensation at P150.00 per square meter. Accordingly,
NAPOCOR was ordered by the RTC to pay defendant
spouses, the amount of Php 150.00 per square meter, as
the just compensation. NAPOCOR appealed to the CA
arguing that the RTC did not apply Section 3A of
R.A. No. 6395 which limits its liability to easement fee of
not more than 10% of the market value of the property
traversed by its transmission lines. On appeal, the CA
affirmed the RTC’s decision.
 ISSUE

Whether or not the RTC erred in fixing the

amount of the just compensation.
 RULING
The Supreme Court held that the payment of just
compensation for private property taken for public
use is guaranteed no less than our Constitution and
is included in the Bill of Rights. Thus, Sec. 3A of
RA No. 6395 nor any legislative enactments nor
executive issuances can prevent the courts from
determining just compensation. Further, it is a
judicial function that cannot be usurped by any
other branch or official of the government. Statutes
and executive issuances fixing or providing for the
method of computing just compensation are not
binding on courts and, at best, are treated as mere
guidelines in ascertaining the amount thereof.