Tiongson v. National Housing Authority
REITERATIONFacts
The Antecedents: Respondent National Housing Authority (NHA) filed a complaint for eminent domain against petitioners, owners of several lots in Tondo, Manila. NHA deposited P21,107,485.07 as provisional just compensation. Petitioners filed motions to dismiss with claims for damages. Procedural History: The Regional Trial Court (RTC) dismissed NHA's complaint and petitioners' counterclaims. The Court of Appeals (CA) affirmed the RTC. This Court declared the case terminated due to NHA's failure to file a petition on time, and the resolution became final and executory. Subsequently, NHA filed a motion to withdraw its deposit. The RTC initially ordered that the deposit be considered advance payment or indemnity for damages, setting the motion for hearing. However, the CA reversed the RTC, directing the release of the deposit to NHA, holding that the dismissal of petitioners' counterclaim barred them from presenting evidence for damages. The Petition: Petitioners seek to set aside the CA's decision and resolution, arguing that the CA committed grave abuse of discretion in granting NHA's motion to withdraw the deposit without proper notice of hearing and before a hearing could be held to determine damages.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction in acting on and granting NHA's motion for withdrawal of deposit without proper notice of hearing, considering the dismissal of the expropriation complaint and the petitioners' compulsory counterclaim for damages. Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction in granting NHA's motion to withdraw its deposit before a hearing on the issue of damages suffered by petitioners, particularly in light of the nature of expropriation proceedings and counterclaims.
Ruling
The petition is denied. The Decision and Resolution of the Court of Appeals dated March 25, 2004 and February 4, 2005, respectively, are affirmed in toto.
Ratio Decidendi
On the issue of withdrawal of deposit without proper notice of hearing and before a hearing on damages: The Court held that the dismissal of the expropriation complaint by the RTC, which also dismissed petitioners' compulsory counterclaim for damages, was affirmed by the CA and became final and executory. Petitioners did not appeal the dismissal of their counterclaim. The Court noted that NHA filed its motion to withdraw the deposit seven years after the dismissal of the complaint became final. During this period, petitioners did not take any action to pursue their claim for damages, such as filing a motion or pleading for a hearing or claiming damages. The Court ruled that this inaction constituted a waiver of their claim and a deprivation of due process, as they had ample time and opportunity to pursue their claim. Therefore, the CA did not commit grave abuse of discretion in ordering the release of the deposit, as the dismissal of the counterclaim effectively barred the claim for damages. On the issue of granting the motion to withdraw the deposit before a hearing on damages, considering the nature of expropriation proceedings and counterclaims: The Court reiterated that expropriation proceedings involve two stages: condemnation and ascertainment of just compensation. It clarified that a compulsory counterclaim is auxiliary to the main proceeding and derives its jurisdictional support therefrom. The dismissal of the main action can result in the dismissal of the counterclaim, especially if the filing of a motion to dismiss the complaint is considered an implied waiver of the counterclaim. The Court distinguished the present case from National Power Corporation v. Court of Appeals (NAPOCOR), where the dismissal of the complaint was made with a reservation to allow the property owner to adduce evidence on damages, and the expropriating authority also moved to dismiss. In this case, the dismissal of the counterclaim was without reservation, and petitioners failed to adduce evidence on their damages.
Main Doctrine
The dismissal of a compulsory counterclaim in an expropriation proceeding, where the property owners did not adduce evidence to prove damages and did not appeal the dismissal of their counterclaim, bars them from claiming damages after the dismissal of the expropriation complaint becomes final and executory. The failure to pursue the claim for damages within the seven years after the finality of the dismissal constitutes a waiver and a deprivation of due process.