Panes v. Visayas State College of Agriculture
REITERATIONFacts
The Antecedents: Presidential Decree (P.D.) No. 1107 authorized the Visayas State College of Agriculture (VISCA) to acquire private agricultural properties through negotiated sale or expropriation for the establishment of the Philippine Root Crops Research and Training Center. VISCA filed an expropriation complaint against petitioners, citing public purposes such as establishing experimental fields, constructing buildings, and conducting research. VISCA deposited P74,050.00, representing the assessed value of the lands for taxation purposes, and prayed for a writ of possession. Procedural History: Petitioners, in their Answer, alleged that the lands were not within the specified area, the deposited amount was insufficient for just compensation, and P.D. Nos. 794 and 1107 were unconstitutional. Tenant-intervenors also filed a motion to intervene, asserting their tenurial rights and the unconstitutionality of P.D. No. 1107. The trial court initially denied VISCA's motion for a writ of possession, citing agrarian laws and the potential prosecution of the judge under P.D. No. 583. Subsequently, the trial court dismissed the expropriation case despite a Temporary Restraining Order (TRO) from the Court of Appeals. The Court of Appeals reversed the dismissal, finding grave abuse of discretion, and ordered the reinstatement of the case. It also ruled that the trial court erred in denying immediate possession, stating that VISCA's authority was clear under P.D. No. 1107 and P.D. No. 42, and that the contention that P.D. No. 42 applied only to untenanted lands was unconvincing. The Petition: Petitioners sought review of the Court of Appeals' decision, arguing that it erred in ordering the issuance of a writ of possession, in ordering the reinstatement of the expropriation proceedings, and in committing grave procedural errors. The Supreme Court affirmed the reinstatement of the case but modified the ruling on the writ of possession.
Issue(s)
Whether the Court of Appeals erred in ordering the issuance of a writ of possession over the properties subject to expropriation. Whether the Court of Appeals erred in ordering the reinstatement of the expropriation proceedings. Whether the Court of Appeals committed grave procedural errors in the disposition of the case.
Ruling
The Supreme Court affirmed the Court of Appeals' decision insofar as it ordered the reinstatement of the expropriation proceedings. However, it modified the ruling regarding the writ of possession. The Court held that the issuance of a writ of possession is contingent upon the payment of just compensation determined by the trial court, in accordance with Section 2, Rule 67 of the Revised Rules of Court, and not merely upon compliance with P.D. No. 1533 or P.D. No. 42, which were declared unconstitutional for allowing executive determination of just compensation.
Ratio Decidendi
On the Issuance of a Writ of Possession: The Court modified the Court of Appeals' ruling that VISCA was entitled to a writ of possession upon compliance with P.D. No. 1533. The Court cited its ruling in Export Processing Zone Authority v. Dulay, which declared P.D. No. 1533, along with similar provisions in P.D. Nos. 42, 76, 464, 794, 1224, 1259, 1313, and 1517, unconstitutional. These decrees were deemed unconstitutional because they converted the determination of just compensation from a judicial prerogative to an executive decision, thereby rendering courts inutile in a matter constitutionally reserved for them. Consequently, any right to immediate possession must now be grounded on a valid compliance with Section 2 of Rule 67 of the Revised Rules of Court, which requires a deposit with the court of the provisionally ascertained value of the property. On the Reinstatement of the Expropriation Proceedings: The Court affirmed the Court of Appeals' finding that the trial court committed precipitate action in dismissing the expropriation case with prejudice. The Court emphasized that P.D. No. 1107, the law under which the expropriation was sought, remained in force and effective, and carried a presumption of constitutionality. Therefore, VISCA was entitled to prosecute its case and be heard on the merits of its claims under P.D. No. 1107. The dismissal was deemed too drastic under the circumstances, especially considering the pending petition for certiorari before the Court of Appeals and VISCA's request for postponement. On Other Assigned Errors: The Court found that the other assigned errors raised by the petitioners involved factual questions, such as whether the properties were within the area specified by P.D. No. 1107 and whether there was a public necessity for the expropriation. These factual matters, the Court stated, needed to be threshed out in the trial court proceedings. The Supreme Court declined to pre-empt the trial court's proceedings or defeat VISCA's statutory rights by prematurely ruling on the constitutionality issues raised.
Main Doctrine
While the reinstatement of an expropriation case dismissed with prejudice is warranted, the issuance of a writ of possession requires a deposit of just compensation determined by the court, not by executive fiat, following the unconstitutionality of decrees that allowed executive determination of such compensation.