16 50. On October 1, 2007 Julio Raúl Moscoso Álvarez,41 proposed by the Commission and the representatives, offered his expert opinion before a notary public, which regards Ecuadorian law and not the value of the lot;42 however, he indicated that the value of the property is set based on the value of the expropriated property when the case file on the occupation is opened, without taking into consideration the added value that results as a direct consequence of the project that led to the expropriation and its future expansions.43 51. The expert opinion offered by the expert Jakeline Jaramillo Barcia,44 presented by the representatives in their brief on reparations on April 13, 2009, before this Court, through which the expert establishes the “urban purpose”45 of the property. To carry out the valuation of the property, the expert used a comparative market approach, which results in an estimate of the property’s value, comparing it with offer prices of similar near by properties,46 which constituted urbanized properties in this case. According to said expert report, the representatives considered that the value of the property’s soil in the year 1991, prior to the declaration of public interest,47 was of US$65.33 per m2,48 corresponding to US$42,180,504.47 41 Cf. Case of Salvador Chiriboga V. Ecuador, supra note 24, para. 19.f), and Expert assessment of Julio Raúl Moscoso Álvarez rendered on October 1, on October 1, 2007 (case file of Merits, tome IV, folios 512 to 548). 42 Mr. Moscoso Alvarez gave his expert opinion on the nature of the declaration of public interest, the process of appeal to the Ministry of the Interior in the Case of expropriation, the formation and revocation of administrative acts, among others. In addition, the expert explained that a tax is in effect for landowners with no edifications within the city limits, who have not raised any constructions on the lands. He also stated that it is not unusual that properties that have been declared for public interest continue to pay property taxes, because given the very lengthy expropriation proceedings, the owners of the properties continue to appear as the land owners in the municipal cadastre, even when they are not occupying the land and even when it is occupied by the State agency that is expropriating it. Cf. Expert assessment of Julio Raúl Moscoso Álvarez, supra note 41, folio 548. 43 Cf. Expert assessment of Julio Raúl Moscoso Álvarez, supra note 41, folio 545. 44 Cf. Expert assessment of Jakeline Jaramillo Barcia rendered in April 2009 (case file of Reparations and Costs, tome II, folios 281 to 297). 45 The expert verified the “urban vocation” of the property in question, due to the specific conditions of its location inside the city of Quito, the existence of infrastructure and services in the area adjacent to the physical conditions of gentle terrain and landscape that could be subject to other urban uses, and also due to the own decision of the municipal authority that assigned the use of equipment since 1980, essential for the construction of the city and the improvement of the quality of life of its inhabitants. In that regard it mentioned that since 1980 the Municipality of Quito, through which “Plan Quito” defined that the plot in question be used as an urban public park, and that that use of the grounds was ratified by the Urban Rules of Procedure of 1989 in its proposal of the Use of Land and of the Environmental and Recreational System. The expert witness added that the ordinance No. 2818 of October 1990 established the boundaries of the Metropolitan Park and that therefore, the Municipality had assigned an important amount of equipment for the City of Quito to these plots. Cf. Expert assessment of Jakeline Jaramillo Barcia, supra note 44, folios 288 a 289). 46 Cf. Expert assessment of Jakeline Jaramillo Barcia, supra note 44, folio 294. 47 The expert noted that the expropriation of municipal governments have historically governed based on the Municipal System Act, and the Code of Civil Procedure as a compliment to it. Therefore, for the expropriation of property declared for public interest, the price of the property would be determined on the basis of the value it has as of the date of commencement of the brief of occupation, regardless of goodwill arising as a direct result of the project motivating the expropriation. Cf. Expert assessment of Jakeline Jaramillo Barcia, supra note 44, folio 293. 48 To evaluate the commercial value of the land, the expert identified five key variables selected to "standardize" the information of the offers on the land, which have been gathered from the newspaper "El Comercio " in the periods of October 1990 and May 1991. From an urban value, it was adjusted considering the key variables, which gave the final value to the property: a) the location (the expert gave a value of factor 1), b) socioeconomic status of the sector where the land is located (the expert gave a value of factor 1), c) the purpose for use (the expert gave a value of factor 1), d) the size of the land (the land in question would be appropriate for housing developments or for recreational purposes which require large tracts of land, the expert gave the value of the factor 0.9), and d) the existence of infrastructure (the expert considers the cost of introducing works of basic services to the property, the expert gave the value of the factor 0.75). In this way, the expert obtained a "coefficient of standardization" of the 0.675 factor, since the factors that are equal to 1 have similar attributes of the land used by the expert to obtain a comparative price. From a commercial reference value of print ads which corresponds to U.S. $ 96.78, the expert arrived at a price of U.S. $ 65.33 for the land in question using the following multiplication: market value U.S. $ / m2 (96.78) x standardizing coefficient (0.675) = final value U.S. $ / m2 (65.33) (case file of Reparations, tome II, folios