Meralco v. Pineda, 206 SCRA 196 (1992)

Meralco v. Pineda, 206 SCRA 196 (1992) 
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FACTS:
October 29, 1974 – A complaint for eminent domain was filed by petitioner MERALCO against 42 defendants with the Court of First Instance of Rizal, Branch XXII, Pasig, Metro Manila alleging that petitioner needs portions of the land of the private respondents consisting of an aggregate area of 237,321 square meters to construct a 230 KV Transmission line from Barrio Malaya to Tower No. 220 at Pililla, Rizal.
Petitioner offered to pay compensation but the parties failed to reach an agreement.
Respondent judge, without the proper reception of evidence before the Board of Commissioners, arrived at the amount of just compensation on its own, merely basing the amount from competent evidence.
The petitioner strongly maintains that the respondent court's act of determining and ordering the payment of just compensation to private respondents without formal presentation of evidence by the parties on the reasonable value of the property constitutes a flagrant violation of the petitioner's constitutional right to due process. It stressed that the respondent court ignored the procedure laid down by the law in determining just compensation because it formulated an opinion of its own as to the value of the land in question without allowing the Board of Commissioners to hold hearings for the reception of evidence.
 
ISSUE: 
 
Whether or not the respondent court can dispense with the assistance of a Board of Commissioners in an expropriation proceeding and determine for itself the just compensation.
 
RULING:
 
The judge flagrantly violated the petitioner’s right to due process when it disregarded the assistance of the Board of Commissioners in the determination of just compensation and subsequently ordering of payment thereof.
In an expropriation case such as this one where the principal issue is the determination of just compensation, a trial before the Commissioners is indispensable to allow the parties to present evidence on the issue of just compensation.
The appointment of at least three (3) competent persons as commissioners to ascertain just compensation for the property sought to be taken is a mandatory requirement in expropriation cases.
While it is true that the findings of commissioners may be disregarded and the court may substitute its own estimate of the value, the latter may only do so for valid reasons, i.e., where the Commissioners have applied illegal principles to the evidence submitted to them or where they have disregarded a clear preponderance of evidence or where the amount allowed is either grossly inadequate or excessive
A trial with the aid of the commissioners is a substantial right that may not be done away with capriciously or for no reason at all.