National Power Corp. vs. Court of Appeals

No. L-56378. June 22, 1984

Main Topic – Rule 67.

FACTS

NPC instituted proceedings for eminent domain against the spouses Sadang purpose of constructing an access road to its Angat River Hydroelectric Project.

the Trial Court appointed three Commissioners, one for each of the parties and another for the Court, to receive the evidence and determine the just compensation to be paid for the property sought to be expropriated.

ISSUE

Whether or not Court erred (1) in fixing the amount of P7.00 per square meter as just compensation for the portion of land sought to be expropriated based on its planned convertibility into a residential subdivision; and (2) in not reducing the rate of interest payable by NPC from twelve (12%) per cent to six (6%) per cent per annum.

RULING

No. The labor officials’ findings on this factual matter are conclusive upon the Court under the well-settled doctrine that factual findings of quasi-judicial agencies are accorded not only respect but also finality if supported by substantial evidence. The finding of good faith on the part of the company, the Court holds that there is no factual or legal basis for an order against the company to grant either back wages or financial assistance in the form of separation pay to petitioners. 

NLRC’s decision can hardly be considered tainted by the arbitrariness or unfairness that is the essence of grave abuse of discretion. Absent a clear showing of grave abuse of discretion on the part of public respondents in deleting the award of financial assistance, the petition must perforce fail.

DOCTRINE

The price or value of the land and its character at the time it was taken by the Government are the criteria for determining just compensation.