National Power Corporation v. Sps. Jose C. Campos, Jr.

Summary

The National Power Corporation (NPC) was granted temporary permission in mid-1970 to install wooden electrical posts on respondents' Cavite property for Puerto Azul electrification. Despite assurances of temporary use, NPC continued occupying the property for over 20 years without compensation. When NPC filed expropriation proceedings in 1995 and made misrepresentations about prior negotiations, respondents sued for damages. The Supreme Court affirmed lower courts' awards of P2,141,239 in damages, ruling that NPC's use was merely by tolerance and could not ripen into prescriptive easement rights. The Court held that NPC's Charter provision on prescription was inapplicable since NPC never actually acquired title to the property, and that moral and nominal damages were proper given NPC's oppressive conduct and violation of constitutional property rights.