De los Reyes v. Capulong
REITERATIONFacts
1. The Antecedents: The Province of Pampanga initiated an expropriation proceeding in 1976 to acquire two parcels of land owned by the petitioners, totaling 46,686 square meters. The Province contended the fair market value was P62,070 and deposited P19,170, plus accrued interest, which the petitioners withdrew. The trial court, however, declared the just compensation to be P7 per square meter, a decision that the Province appealed. 2. Procedural History: Following the trial court's decision setting the just compensation, the Province of Pampanga appealed to the Court of Appeals. Concurrently, the petitioners sought immediate execution of the judgment pending appeal, a motion that was denied by the respondent judge. This denial of the motion for immediate execution is the subject of the current petition before this Court. 3. The Petition: The petitioners are assailing the respondent judge's order denying their motion for immediate execution pending appeal. They argue that the Province should pay P42,900, including P8,335.72 in interest, citing precedent. The Province counters that interest was not awarded in the trial court's decision. The Supreme Court directed the Province to immediately pay P34,564.28 without prejudice to the determination of interest liability in the main case and allowed the petitioners to refile their motion for execution pending appeal in the appellate court.
Issue(s)
Whether the Province of Pampanga should be compelled to pay the petitioners the sum of P34,564.28 immediately, and whether the Province should be compelled to pay the remaining P8,335.72, inclusive of accrued interest, pending appeal. Whether the denial of the motion for immediate execution pending appeal was proper, and if so, what procedural steps should the petitioners take.
Ruling
The Province of Pampanga was directed to pay immediately the sum of P34,564.28 to the petitioners or their counsel, without prejudice to the subsequent determination of the Province's liability for interest. The issue of whether the sum of P8,335.72 should be treated as interest or included in the principal would be adjudicated in the main case pending in the Intermediate Appellate Court. The petitioners were also advised that they may refile their motion for execution pending appeal in the main case should the decision therein be delayed.
Ratio Decidendi
On the issue of immediate payment of P34,564.28: The Court acknowledged that there was no controversy as to the sum of P34,564.28 and directed the Province of Pampanga to pay this amount immediately to the petitioners. This partial payment was made without prejudice to the final determination of the Province's liability for the remaining amount, including interest. The Court's directive for immediate payment of the undisputed amount aims to provide some relief to the landowners while the main issue of just compensation and interest is being resolved by the appellate court. On the issue of the motion for execution pending appeal: The Court addressed the motion for execution pending appeal, noting that such execution may be granted provided the movant files a good and sufficient surety bond. The Court advised the petitioners to refile their motion for execution pending appeal in the Intermediate Appellate Court if the decision in the main case is unduly delayed. This approach balances the need for potential further payment with the pendency of the appeal and the procedural requirements for execution pending appeal. The Court's guidance on refiling the motion for execution pending appeal in the appellate court is a procedural instruction to ensure that the proper forum handles such requests in light of the ongoing appeal.
Main Doctrine
The Province of Pampanga was directed to pay immediately a sum certain without prejudice to the subsequent determination of its liability for interest, and the petitioners were advised to refile their motion for execution pending appeal in the appellate court if the decision therein is delayed.