Delayed Just Compensation in Philippine Jurisprudence, 1909–2026: Legal Interest and the Compounded Adjustment

Philippine courts have recognized since 1909 that an owner whose property is taken before it is paid for suffers a loss beyond the value of the property, and for most of the following century they answered that loss with legal interest. Compounded present-value adjustment is more recent. It was adopted in the majority opinion in Republic v. Spouses Nocom (2021) and applied in Heirs of Mariano (2022), Heirs of Cipriano (2025) and Spouses Baterna (2026). This study asks why interest was the remedy for so long and what explains the later adjustment. It reviews fourteen Supreme Court cases, chosen by three stated criteria, from Philippine Railway Co. v. Solon (1909) to Baterna (2026), and it separates what each decision held, what follows from the holding doctrinally, and what the author infers economically.