Republic v. Heirs of Luis Santos
REITERATIONFacts
1. The Antecedents: Petitioner, Republic of the Philippines, represented by the Philippine Information Agency (PIA), instituted expropriation proceedings in 1969 to acquire 544,980 square meters of land for broadcast operations. A provisional deposit of P517,558.80 was made. In 1979, the Regional Trial Court (RTC) of Bulacan condemned the properties and ordered petitioner to pay just compensation at P6.00 per square meter, with legal interest from September 19, 1969. 2. Procedural History: The national government failed to pay the compensation. In 1984, the heirs of Luis Santos (predecessor-in-interest of respondents) filed a motion for payment, and the RTC issued a writ of execution. A portion of the initial deposit (P72,683.55) was released to the heirs. Meanwhile, President Estrada transferred 20 hectares of the expropriated property to Bulacan State University and 5 hectares for carabao propagation. In 1999, petitioner filed a motion to deposit P4,664,000.00 as just compensation. The heirs opposed, seeking adjustment to P5,000.00 per square meter or the return of the property. On March 1, 2000, the RTC vacated its 1979 decision, declaring it unenforceable due to prescription, and ordered the return of the property. 3. The Petition: The Court of Appeals denied petitioner's petition for certiorari. The Supreme Court granted the petition, setting aside the CA resolution and the RTC decision, and remanding the case for execution of the 1979 decision.
Issue(s)
Whether the RTC erred in declaring the 1979 judgment unenforceable due to prescription. Whether the respondents are entitled to the return of the expropriated property. Whether the Court of Appeals erred in dismissing the petition for certiorari.
Ruling
The petition is GRANTED. The resolution of the Court of Appeals dismissing the petition for certiorari, as well as its resolution denying the motion for reconsideration, and the decision of the Regional Trial Court of Bulacan, dated March 1, 2000, are SET ASIDE. The case is forthwith remanded to the Regional Trial Court of Bulacan for the proper execution of its decision promulgated on February 26, 1979, which is hereby REINSTATED.
Ratio Decidendi
On the issue of prescription and enforceability of the 1979 judgment: The Supreme Court held that the RTC erred in declaring the 1979 judgment unenforceable due to prescription. While Section 6, Rule 39 of the Rules of Court provides a five-year period for execution by motion, the Court found that the actions taken by the respondents in filing motions for payment in 1984 and the subsequent release of a portion of the deposited sum constituted acts that could interrupt the prescriptive period. The Court emphasized that the expropriation proceeding, being an in rem action, vests paramount title in the public upon condemnation, and the condemnor exercises dominion over the property. This exercise of dominion amounts to at least partial compliance, preempting claims of bar by prescription. Furthermore, the Court noted that the respondents' own delay in seeking payment from 1979 to 1984 could also be viewed as laches against them, reinforcing the idea that the judgment should be executed rather than vacated. On the entitlement to the return of the expropriated property: The Supreme Court ruled that the respondents are not entitled to the return of the expropriated property. Citing Valdehueza vs. Republic and Alfonso vs. Pasay City, the Court reiterated that once property is condemned for public use and is still devoted to such use, the landowner's remedy is to demand just compensation, not recovery of possession. The Court distinguished the case from Provincial Government of Sorsogon vs. Vda. de Villaroya, noting that the latter involved a delegated power of eminent domain with limited application, unlike the inherent power of the national government. The Court clarified that the expropriatory authority's right is not akin to an unpaid seller in ordinary sales, where rescission might apply, as condemnation proceedings vest a new and independent title in the public. On the Court of Appeals' dismissal of the petition for certiorari: The Supreme Court found that the CA erred in dismissing the petition. The Court acknowledged the confusion surrounding the reglementary periods for filing a petition for certiorari, particularly with the amendments to Section 4, Rule 65 of the Rules of Civil Procedure. However, the Court ultimately gave due course to the petition, deeming it imbued with public interest, and resolved the case on its merits. The Court's decision to set aside the CA's resolution indicates that the CA should have addressed the merits of the case rather than dismissing it on procedural grounds related to the prescriptive period for execution.
Main Doctrine
The failure to execute a final and executory judgment within the prescriptive period renders it unenforceable by mere motion. However, partial compliance or acknowledgment of the judgment by the condemnor, or the receipt of partial payment by the landowner, may interrupt the prescriptive period. The landowner is entitled to just compensation, which includes legal interest from the time of taking until full payment, and is not entitled to recover possession of the expropriated property if it continues to be devoted to public use.