San Juan v. Tan
REITERATIONFacts
The Antecedents: The Province of Rizal initiated eminent domain proceedings to acquire 30,420 square meters of urban land owned by the petitioners. The stated purpose was to construct public buildings and expand the Morong High School facilities. The province was granted possession of the land, and a Committee on Appraisers was appointed to value it. The committee conducted hearings and submitted its report. Procedural History: Following the submission of the appraisers' report, the petitioners requested a hearing, which was scheduled for February 20, 1953. The Provincial Fiscal's Office was notified. On March 30, 1953, the respondent judge issued a decision fixing the land's price at P1.50 per square meter for riceland and bacood, and P3 per square meter for residential land, totaling P4,510, plus additional damages for fruit-bearing trees and a house. This decision became final and executory. Subsequently, on May 12, 1953, the court ordered the issuance of a writ of execution. However, on June 19, 1953, the respondent judge revoked the March 30, 1953 decision, citing an error in not serving copies of the appraisers' report to all parties and not allowing them ten days to file objections, as required by Rules 8 and 9 of the Rules of Court. The Petition: The petitioners are seeking a writ of certiorari to nullify the respondent judge's order of June 19, 1953, which revoked a prior final and executory decision. They argue that the respondent judge lost jurisdiction to modify the decision after it had become final and executory, except for clerical corrections. The petitioners contend that the province waived its right to object to the appraisers' report by failing to raise the issue at any point before the decision became final, despite numerous opportunities to do so.
Issue(s)
Whether the respondent Judge committed grave abuse of discretion in revoking a final and executory decision in an expropriation case. Whether the failure of the province to file objections to the commissioners' report and its subsequent inaction after the decision became final constituted a waiver of its right to question the report or the decision.
Ruling
The Supreme Court declared the order of the respondent Judge dated June 19, 1953, null and void and of no force and effect. The Court ordered that there be no special pronouncement as to costs.
Ratio Decidendi
On Whether the respondent Judge committed grave abuse of discretion in revoking a final and executory decision in an expropriation case: The Court held that the respondent Judge committed grave abuse of discretion amounting to lack of jurisdiction. Once a decision in an expropriation case becomes final and executory, the court loses all jurisdiction to modify or set it aside, except for clerical errors. The decision of March 30, 1953, had become final and executory, and the court's subsequent order of June 19, 1953, revoking that decision, was an act performed without jurisdiction. The court emphasized that the proper remedy for a party aggrieved by a final and executory judgment is not to seek its revocation by the same court, but to pursue other legal remedies available, if any, within the prescribed periods. On Whether the failure of the province to file objections to the commissioners' report and its subsequent inaction after the decision became final constituted a waiver of its right to question the report or the decision: The Court ruled that the province, through its inaction, had waived its right to question the commissioners' report and the subsequent decision. The province was aware of the report's existence and had opportunities to request a copy and file objections, both before and after the decision was rendered. Its failure to do so, and its subsequent silence while the decision became final and executory, implied acquiescence or conformity to the decision. The notification of the report and the ten-day period for objections are rights that can be waived, and such waiver is understood when not invoked at the opportune time. The omission of these procedural requirements did not affect any essential right or the jurisdiction of the court, nor did it render the decision void ab initio.
Main Doctrine
The Supreme Court reiterated that a court loses all jurisdiction to modify a decision that has become final and executory, except for the correction of clerical errors. In expropriation proceedings, the failure of a party to raise objections to the commissioners' report within the prescribed period, or to move for reconsideration or appeal a final decision, constitutes a waiver of such rights. Consequently, any subsequent order attempting to modify or revoke a final and executory decision is void and without effect.