GR 143643; (June, 2003) (Digest)
G.R. No. 143643 ; June 27, 2003
NATIONAL POWER CORPORATION, petitioner, vs. SPS. JOSE C. CAMPOS, JR. and MA. CLARA LOPEZ-CAMPOS, respondents.
FACTS
The respondents, Spouses Campos, own a parcel of land in Dasmariñas, Cavite. In the 1970s, they verbally allowed the National Power Corporation (NPC) to install temporary wooden posts and transmission lines on a portion of their property, with the understanding that these would be relocated once permanent facilities were installed. NPC, however, continued to use the property without compensation. In 1994 and 1995, NPC’s agents trespassed on the land to conduct surveys for a new all-steel transmission tower, even presenting a forged letter of authority. The respondents refused permission and demanded the agents leave.
In December 1995, NPC filed an expropriation case for a right-of-way over the property. The respondents, alleging NPC acted in a whimsical, capricious, and oppressive manner, filed a separate action for sum of money and damages. They claimed NPC’s actions, including the unauthorized entry and the expropriation suit filed despite the existence of more suitable alternative sites, devalued their property and forced them into litigation. The trial court declared NPC in default for failing to file a proper answer.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s award of actual, moral, and nominal damages, and attorney’s fees to the respondents.
RULING
The Supreme Court denied NPC’s petition and affirmed the damages awarded. The legal logic is anchored on NPC’s abuse of its right and the violation of the respondents’ property rights. While NPC possesses the statutory power of eminent domain, this power must be exercised within the bounds of law and with due regard for the property owner’s rights. NPC’s actions—the prolonged unauthorized use of the property without compensation, the repeated trespassing, the use of a forged authorization, and the filing of an expropriation case allegedly without genuine negotiation and despite the availability of less injurious alternatives—constituted evident bad faith and an oppressive exercise of its authority.
This abuse justified the award of moral damages under Article 2220 of the Civil Code, as the respondents, persons of established reputation, suffered mental anguish, serious anxiety, and besmirched reputation due to NPC’s wanton and high-handed acts. Nominal damages were properly awarded under Articles 2221 and 2222 to vindicate the respondents’ invaded property rights. Attorney’s fees were also warranted as the respondents were compelled to litigate to protect their interests. The Court emphasized that the state’s power of eminent domain, when delegated to entities like NPC, does not grant a license to disregard legal norms and the rights of citizens.