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NATIONAL POWER CORPORATION v. ZAIN B. ANGAS

This case has been cited 6 times or more.

	GR No. 179334 2015-04-21	SECRETARY OF DEPARTMENT OF PUBLIC WORKS v. SPS. HERACLEO AND RAMONA TECSON PERALTA, J.
We have in the past been confronted with the same issues under similar factual and procedural circumstances. We find no reason to depart from the doctrines laid down in the earlier cases as we adopted in the assailed decision. In this regard, we reiterate the doctrines laid down in the cases of Forfom Development Corporation (Forfom) v. Philippine National Railways (PNR),[10] Eusebio v. Luis,[11] Manila International Airport Authority v. Rodriguez,[12] and Republic v. Sarabia.[13]
	GR No. 179334 2015-04-21	SECRETARY OF DEPARTMENT OF PUBLIC WORKS v. SPS. HERACLEO AND RAMONA TECSON PERALTA, J.
Previous jurisprudence[58] cited the use of Act No. 2655 and Central Bank circulars issued in relation to that law as basis for the use of 6% and 12%. Act No. 2655 is a law that determines a ceiling interest rate to avoid usurious loans. Throughout the text of the law, reference is made to a "person" or "corporation." This law is not nuanced to fit the purposes of determining just compensation in favor of a private property owner. The transaction involved here is not a loan or forbearance of money between two private parties but expropriation, an exercise of eminent domain powers of the state. The use of usury laws and circulars in order to determine "just compensation" in case of delay is as crude as it is imprecise.
	GR No. 183137 2013-04-10	PELIZLOY REALTY CORPORATION v. PROVINCE OF BENGUET LEONEN, J.
The purpose and rationale of the principle was explained by the Court in National Power Corporation v. Angas[18] as follows: The purpose of the rule on ejusdem generis is to give effect to both the particular and general words, by treating the particular words as indicating the class and the general words as including all that is embraced in said class, although not specifically named by the particular words. This is justified on the ground that if the lawmaking body intended the general terms to be used in their unrestricted sense, it would have not made an enumeration of particular subjects but would have used only general terms. [2 Sutherland, Statutory Construction, 3rd ed., pp. 395-400]. [19]
	GR No. 164195 2010-10-12	APO FRUITS CORPORATION v. LAND BANK OF PHILIPPINES BRION, J.
Aside from this ruling, Republic notably overturned the Court's previous ruling in National Power Corporation v. Angas[16] which held that just compensation due for expropriated properties is not a loan or forbearance of money but indemnity for damages for the delay in payment; since the interest involved is in the nature of damages rather than earnings from loans, then Art. 2209 of the Civil Code, which fixes legal interest at 6%, shall apply.
	GR No. 124795 2008-12-10	FORFOM DEVELOPMENT CORPORATION v. PHILIPPINE NATIONAL RAILWAYS CHICO-NAZARIO, J.
Admittedly, the PNR's occupation of Forfom's property for almost eighteen (18) years entitles the latter to payment of interest at the legal rate of six (6%) percent on the value of the land at the time of taking until full payment is made by the PNR.[52]
	GR No. 172410 2008-04-14	REPUBLIC v. HOLY TRINITY REALTY DEVELOPMENT CORP. CHICO-NAZARIO, J.
The TRB reminds us that there are two stages[11] in expropriation proceedings, the determination of the authority to exercise eminent domain and the determination of just compensation. The TRB argues that it is only during the second stage when the court will appoint commissioners and determine claims for entitlement to interest, citing Land Bank of the Philippines v. Wycoco[12] and National Power Corporation v. Angas.[13]