Public Estates Authority v. Rosario Ganac Chu

Summary

This case involved property damage when the Public Estates Authority bulldozed respondent's pepper plantation without notice in 1993. The Regional Trial Court and Court of Appeals awarded P2,000,000.00 in actual damages, but the Supreme Court modified this decision, finding the amount unsubstantiated by competent evidence. The Court applied the abuse of rights principle under Civil Code Article 19, holding that while PEA may have owned the land, it still had to exercise its property rights with justice and good faith. The Supreme Court reduced the award to P250,000.00 in temperate damages, emphasizing that actual damages must be proven with reasonable certainty through competent evidence, not mere testimony. The case establishes important precedent on the limitations of property rights and the requirement for due process even by property owners.