Key legal question
Whether the non-zoning of the Planggli parcels amounted to compensable material expropriation.
Extracted holding
No. The parcels were not sufficiently serviced or ready for construction, and no special reliance interests justified compensation.
Extracted reasoning
The land lacked adequate road access and an overall development plan; the owners had not incurred significant construction-related costs. A non-zoning generally gives no right to compensation, and the exceptional criteria were not met.