Bardillon v. Barangay Masili of Calamba, Laguna
REITERATIONFacts
The Antecedents: Respondent Barangay Masili filed two complaints for eminent domain to expropriate a 144-square meter parcel of land owned by petitioner Devorah E. Bardillon for the purpose of constructing a multi-purpose hall. - The first complaint (Civil Case No. 3648) was filed before the Municipal Trial Court (MTC) of Calamba, Laguna, on February 23, 1998, after negotiations for the purchase of the land for P200,000.00 failed. The MTC dismissed this case on March 5, 1999, for lack of interest due to the failure of the respondent and its counsel to appear at the pre-trial. The MTC denied the respondent's motion for reconsideration on May 3, 1999. - The second complaint (Civil Case No. 2845-99-C) was filed before Branch 37 of the Regional Trial Court (RTC) of Calamba, Laguna, on October 18, 1999. Petitioner opposed this complaint via a Motion to Dismiss, arguing that the cause of action was barred by prior judgment (res judicata). - On January 21, 2000, the RTC denied the Motion to Dismiss, holding that the MTC had no jurisdiction over the expropriation proceeding. - Subsequently, Municipal Ordinance No. 2000-261 was approved, authorizing the expropriation. On August 4, 2000, the RTC issued an order in favor of Barangay Masili, and on August 16, 2000, a Writ of Possession was issued. Procedural History: The Court of Appeals (CA) dismissed petitioner's Petition for Certiorari, finding that the RTC did not commit grave abuse of discretion in issuing its orders. The CA ruled that the second complaint was not barred by res judicata because the MTC lacked jurisdiction over the first expropriation case. The Petition: Petitioner seeks to set aside the CA's Decision and Resolution, arguing that the CA committed grave abuse of discretion in denying her appeal and in its rulings on jurisdiction, res judicata, entry into premises, and forum shopping.
Issue(s)
Whether the Municipal Trial Court (MTC) had jurisdiction over the expropriation case. Whether the dismissal of the first expropriation case before the MTC constituted res judicata. Whether the Court of Appeals (CA) erred when it ignored the issue of the legality of entry upon the premises and the issuance of a Writ of Possession despite a pending Motion for Reconsideration. Whether respondent Barangay Masili is guilty of forum shopping.
Ruling
The Petition is denied, and the assailed Decision of the Court of Appeals is affirmed. Costs are against the petitioner.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that an expropriation suit is incapable of pecuniary estimation and falls within the exclusive original jurisdiction of the Regional Trial Courts (RTCs), regardless of the value of the subject property. This is because the primary consideration in such a suit is the government's exercise of eminent domain, not merely the recovery of a sum of money or the property's monetary value. The determination of just compensation is merely an incidental aspect, which occurs only after the court has established the propriety of the expropriation itself. Citing Barangay San Roque v. Heirs of Francisco Pastor, the Court explained that the subject of an expropriation suit is the government's exercise of eminent domain, a matter that is inherently incapable of pecuniary estimation. Furthermore, Republic of the Philippines v. Zurbano established that condemnation proceedings are within the jurisdiction of Courts of First Instance (the forerunners of RTCs), a principle that was upheld under Batas Pambansa Bilang 129 (BP 129), as amended by Republic Act No. 7691 (RA 7691). Thus, the Municipal Trial Court (MTC) lacked subject matter jurisdiction over the first expropriation complaint. On Issue 2: The Supreme Court held that the doctrine of res judicata finds no application in this case because one of its essential requisites, namely, that the former judgment must have been rendered by a court of competent jurisdiction over the subject matter and the parties, was absent. Res judicata means a matter adjudged, judicially acted upon or decided, or settled by judgment, requiring a final judgment on the merits rendered by a competent court to be an absolute bar to subsequent actions. Since the Municipal Trial Court (MTC) had no jurisdiction over expropriation proceedings, its dismissal of the first complaint, even if considered an adjudication on the merits, could not constitute a final judgment that would bar a subsequent action. A judgment rendered by a court without jurisdiction is void and can produce no legal effects, thus it cannot serve as a basis for res judicata to preclude the Regional Trial Court (RTC) from taking cognizance of the second complaint. Therefore, the filing of the second complaint before the RTC was not barred by prior judgment. On Issue 3: The Supreme Court found that the issuance of the Writ of Possession in favor of respondent Barangay Masili was proper. The Court emphasized that the requisites for the immediate issuance of a writ of possession in an expropriation case are expressly governed by Section 2 of Rule 67 of the 1997 Rules of Civil Procedure and Section 19 of the Local Government Code. These requisites include the filing of a complaint for expropriation sufficient in form and substance, and the deposit of an amount equivalent to 15 percent of the fair market value of the property based on its current tax declaration, as established in Biglang-awa v. Bacalla. Since Barangay Masili had complied with these requirements by filing the complaint and making the necessary deposit, the RTC correctly issued the writ. Any objection to the necessity of the expropriation or the takeover of the property should be raised by the petitioner in her Answer to the Complaint before the RTC, which possesses the power to inquire into such matters, as reaffirmed in cases like Moday v. Court of Appeals and Republic of the Philippines v. La Orden de PP. Benedictinos de Filipinas. On Issue 4: The Supreme Court ruled that respondent Barangay Masili was not guilty of forum shopping. The test for determining the presence of forum shopping is whether the elements of litis pendentia are present in two or more pending cases, such that a final judgment in one case will amount to res judicata in another, as articulated in Heirs of Victorina Motus Peñaverde v. Heirs of Mariano Peñaverde. In this instance, the earlier case lodged with the Municipal Trial Court (MTC) had already been dismissed when the second complaint was filed before the Regional Trial Court (RTC). Crucially, even granting arguendo that both cases were still pending, a final judgment from the MTC would not have constituted res judicata in the RTC case, precisely because the MTC lacked jurisdiction over the expropriation proceedings. Therefore, the act of filing the second complaint in the proper court (RTC) after the dismissal of the first in an incompetent court (MTC) did not amount to forum shopping.
Main Doctrine
An expropriation suit is incapable of pecuniary estimation and thus falls within the jurisdiction of the Regional Trial Courts, regardless of the value of the subject property, because the subject of the action is the government's exercise of eminent domain.