Santos v. Land Bank of the Philippines
REITERATIONFacts
1. The Antecedents: Petitioner Edgardo Santos sought just compensation for agricultural lands expropriated by the DAR under Presidential Decree No. 27 in 1972. The Regional Trial Court (RTC), acting as an agrarian court, initially fixed the just compensation at P49,241,876.00. A preliminary valuation of P3,543,070.66 had already been paid by the Land Bank of the Philippines (LBP) in cash and bonds. The RTC ordered the LBP to pay the remaining balance of P45,698,805.34 in the manner provided by Republic Act (RA) No. 6657. 2. Procedural History: The LBP appealed the RTC decision to the Supreme Court, which dismissed the appeal. A writ of execution was issued, and the LBP made a partial payment of P3,621,023.01 in cash and P41,128,024.81 in Land Bank Bonds. The petitioner moved for an alias writ of execution, seeking a different proportion of cash and bonds, and later moved for the release of the balance, claiming the bonds were unacceptable and demanded cash or certified check. The LBP opposed, asserting the judgment was satisfied. The RTC initially ordered the LBP to release the balance in cash or certified check but later reconsidered, ordering payment of P5,792,084.37 in cash and P35,336,840.16 in government instruments or bonds, in accordance with RA 6657. The petitioner's motion for reconsideration was denied. The petitioner then filed a petition for certiorari and mandamus with the Court of Appeals (CA), which dismissed the petition and affirmed the RTC's order. 3. The Petition: Petitioner filed a Petition for Review on Certiorari with the Supreme Court, challenging the CA's decision. The core issue was whether the RTC's April 24, 1998 Order, which clarified the payment of just compensation in cash and bonds as mandated by RA 6657, constituted an illegal amendment of the final judgment. Petitioner argued that the RTC acted without jurisdiction and that the LBP's compliance with the writ of execution and notice of garnishment should have been treated as an undertaking to pay the entire amount in cash. The Supreme Court, however, found that the RTC's order did not amend the judgment but merely iterated and clarified its essence in accordance with RA 6657, holding that the execution must conform to the final judgment and that the LBP had complied with its obligation by paying in the prescribed proportion of cash and bonds.
Issue(s)
Whether the respondent judge acted without jurisdiction when she issued the Order dated April 24, 1998, amending the final Judgment dated August 12, 1997. Whether it is a ministerial duty of the respondent judge to order the release and of the Land Bank to release the garnished amount under Section 9(c) of Rule 39 of the Rules of Court. Whether respondent Land Bank may question the legality of its own compliance with the Writ of Execution. Whether the respondent judge and the respondent Land Bank and its officials are liable for damages under Section 3 of Rule 65 of the Rules of Court.
Ruling
The Supreme Court denied the petition and affirmed the assailed Court of Appeals decision. The April 24, 1998 Order of the RTC was deemed proper and not an illegal amendment of the final judgment. The Land Bank was found to have complied with its obligation by paying the just compensation in the manner provided by R.A. 6657, which allows for payment in both cash and bonds.
Ratio Decidendi
On the issue of whether the respondent judge acted without jurisdiction when she issued the Order dated April 24, 1998, amending the final Judgment dated August 12, 1997: The Court ruled that the April 24, 1998 Order was not an illegal amendment but an iteration and clarification of the final judgment. The original judgment mandated payment "in the manner provided by R.A. 6657," which, according to Section 18 of the law, involves payment in both cash and bonds. The assailed Order merely specified the exact amounts to be paid in cash and in bonds, thereby making clear the essence of the final judgment. The RTC, in issuing this order, was exercising its general supervisory control over the process of execution of its final and executory decision, especially when special circumstances attending its execution impelled such clarification. Therefore, the judge did not act without jurisdiction. On the issue of whether it is a ministerial duty of the respondent judge to order the release and of the Land Bank to release the garnished amount under Section 9(c) of Rule 39 of the Rules of Court: The Court held that the petitioner's reliance on Section 9, Rule 39 of the Rules of Court was misplaced. While this rule pertains to the delivery of money judgments, it must be read in conjunction with R.A. 6657, which governs the mode of compensation in agrarian reform cases. The Land Bank's compliance with the writ of execution and notice of garnishment should have been construed as an agreement to pay in the manner set forth in R.A. 6657, not solely in cash. Since the Land Bank had already paid the entire adjudged amount in the required proportion of cash and bonds, it had complied with its duty under Rule 39, as modified by R.A. 6657. Thus, ordering the release of the entire amount in cash was not a ministerial duty. On the issue of whether respondent Land Bank may question the legality of its own compliance with the Writ of Execution: The Court found this contention without merit. The Land Bank was obliged to follow the mandate of the final judgment, which was to pay in accordance with R.A. 6657. Its compliance with the writ of execution and notice of garnishment was not an undertaking to pay solely in cash, as such an act would deviate from the final judgment. The bank correctly resisted the petitioner's demand for full cash payment because it would have been a deviation from the terms of the judgment. Therefore, the bank was within its rights to question the petitioner's claim for the balance in cash. On the issue of whether the respondent judge and the respondent Land Bank and its officials are liable for damages under Section 3 of Rule 65 of the Rules of Court: The Court denied this claim. As established, the Land Bank was within its rights in resisting the petitioner's claim for full cash payment, as its actions were in compliance with the law and the final judgment. Consequently, there was no basis to hold the respondent judge or the Land Bank officials liable for damages. The petition, therefore, lacked merit.
Main Doctrine
An order clarifying the mode of payment of just compensation, as mandated by RA 6657, during the execution of a final and executory judgment is not an illegal amendment but a mere iteration and clarification of the said judgment, especially when the original judgment already stipulated payment 'in the manner provided by R.A. 6657'.