Normally, the time of the taking coincides with the filing of the complaint for expropriation. Hence, many rulings of the Court have equated just compensation with the value of the property as of the time of filing of the complaint consistent with the Rules. So too, where the institution of the action precedes entry to the property, the just compensation is to be ascertained as of the time of filing of the complaint.
The general rule, however, admits of an exception: where the Court fixed the value of the property as of the date it was taken and not the date of the commencement of the expropriation proceedings. (NPC v. Ibrahim, et al., G.R. No. 168732, June 29, 2007).