Felisa Agricultural Corp. v. NTC, G.R. Nos. 231655 and 231670, July 02, 2018 - Synopsis Only
Understanding the Supreme Court Decision and Its Impact on Landowners
The case of Felisa Agricultural Corporation (FAC) vs. National Power Corporation (NPC) revolves around a legal dispute concerning transmission towers and lines constructed on FAC-owned land in Brgy. Felisa, Bacolod City.
Case Summary
Felisa Agricultural Corporation filed a complaint against NPC seeking recovery of possession with damages or just compensation for the transmission infrastructure built on its property. NPC argued that it had obtained permission in 1989 to enter the land and construct the 138 KV Mabinay-Bacolod Transmission Line, which had been operational for over ten years, thereby establishing a continuous easement of right-of-way.
The primary issue before the Court of Appeals was whether the case should be governed by Rule 67 of the Rules of Court or Republic Act No. 8974 (R.A. No. 8974). The Supreme Court ultimately reversed the appellate court’s decision, ruling that R.A. No. 8974 should apply. This law mandates that landowners be compensated at 100% of the property’s current zonal value, instead of merely depositing the assessed value as prescribed under Rule 67—a ruling significantly more favorable to landowners.
Key Legal Principles
Expropriation Compensation: Upon filing an expropriation complaint, the government may take possession of private land by depositing its assessed value with an authorized depository.
Exception Under R.A. No. 8974: For national government projects, full compensation must be paid at 100% of the zonal value before expropriation.
Why This Case Matters
This Supreme Court ruling reinforces landowners’ rights to fair compensation, setting a legal precedent for future expropriation cases involving government infrastructure projects.