Philippine Ports Authority v. Rosales-Bondoc
REITERATIONFacts
The Antecedents: The Philippine Ports Authority (PPA) initiated an expropriation of 185 lots, totaling 1,298,340 square meters, for the development of Phase II of the Batangas Port Zone, as mandated by Executive Orders No. 385 and 431. The PPA proposed a market value of P336.83 per square meter, but the trial court authorized immediate possession upon PPA's deposit of an amount equivalent to the assessed value, which was later set at P400.00 per square meter. The landowners, represented by various counsels, sought just compensation significantly higher, with most praying for P8,000.00 per square meter. Procedural History: The Regional Trial Court (RTC) appointed commissioners to determine just compensation, who initially recommended P4,800.00 per square meter. After considering evidence, including an amicus curiae's valuation and prior land sales, the RTC, on August 15, 2000, fixed the just compensation at P5,500.00 per square meter. The RTC subsequently issued several orders directing PPA to pay this amount, with some orders becoming final and executory as PPA did not appeal them. PPA appealed the August 15, 2000 order to the Court of Appeals (CA), which dismissed the appeal, finding the order interlocutory and noting PPA's failure to present evidence. PPA also filed petitions for certiorari and a petition to cite the judge in contempt, which were consolidated with the appeal. The CA ultimately dismissed PPA's petitions and appeal, lifting any injunctions. The Petition: The Philippine Ports Authority filed a Petition for Review on Certiorari with the Supreme Court, assailing the Court of Appeals' Resolution that dismissed its appeal and petitions. PPA argued that the trial court's August 15, 2000 order fixing just compensation was interlocutory and thus not appealable, and that the subsequent execution orders were issued with grave abuse of discretion. PPA also contended that the trial court lacked jurisdiction to issue certain orders due to pending appeals and that the judge should be cited for contempt. The Supreme Court denied the petition, affirming the CA's decision, and directed the trial court to implement its final and executory orders, including the P5,500.00 per square meter compensation, with interest, and to adjust the zonal valuation from P400.00 to P4,250.00 per square meter for industrial classification.
Issue(s)
Whether the Court of Appeals erred in dismissing petitioner’s appeal from the trial court’s Order dated August 15, 2000 setting the fair market value or expropriation price at ₱5,500.00 per square meter of the expropriated lots. Whether the December 14, 2004 Petition for Certiorari assailing the trial court’s Orders and issuances has merit. Whether the trial court gravely abused its discretion in issuing the Order dated November 24, 2004 granting respondents’ "Motion for Immediate Payment of Deficiency in the Zonal Valuation" from ₱400 per square meter to ₱4,250.00 per square meter. Whether Judge Paterno V. Tac-an should be cited in contempt of court for further hearing Civil Case No. 5447 despite the Resolution dated June 3, 2005 of the Court of Appeals directing him to cease and desist from doing so.
Ruling
The Supreme Court denied the petition and affirmed the Resolution of the Court of Appeals. The Temporary Restraining Order (TRO) issued on August 7, 2006, was lifted. The trial court was directed to implement its final and executory Orders requiring PPA to pay just compensation at ₱5,500.00 per square meter, with 12% interest per annum from September 11, 2001, until fully paid. The zonal value was increased from ₱400.00 to ₱4,250.00 per square meter, with the initial deposit to be deducted.
Ratio Decidendi
On the first issue (appealability of the August 15, 2000 Order): The Supreme Court affirmed the Court of Appeals' ruling that the trial court's Order dated August 15, 2000, fixing the fair market value at ₱5,500.00 per square meter, was interlocutory and therefore not appealable. Citing Investments, Inc. v. Court of Appeals, the Court reiterated that a final order finally disposes of the case, leaving nothing more to be done, whereas an interlocutory order does not end the court's task. The August 15, 2000 Order did not adjudicate the merits of the case or declare the rights and obligations of the parties, thus remaining interlocutory. The Court also noted that PPA failed to present evidence before the Commissioners or the trial court, making its arguments for a lower valuation mere legal conclusions without factual basis. The evidence presented by respondents, including expert testimony and prior sales, supported the valuation. The Court emphasized that PPA's documentary evidence were not formally offered, violating Rule 132, Section 34 of the Rules of Evidence. On the second issue (Petition for Certiorari): The Supreme Court found that PPA's Petition for Certiorari, filed on December 14, 2004, assailing the May 29, 2001 Order granting execution, was filed beyond the 60-day reglementary period prescribed by Section 4, Rule 65 of the Rules of Civil Procedure, as PPA received the May 29, 2001 Order on June 4, 2001. Therefore, the petition was dismissed for being filed late. Furthermore, even if the petition were timely, the trial court did not commit grave abuse of discretion in issuing the writ of execution for the August 23, 2000 Order, as PPA did not appeal this specific order, allowing it to become final and executory. On the third issue (Grave abuse of discretion in the deficiency payment order): The Supreme Court found no grave abuse of discretion on the part of the trial court in issuing the Order dated November 24, 2004, granting the motion for immediate payment of deficiency. The Court noted that the trial court used the BIR's zonal valuation for industrial lots, which was a relevant factor under R.A. No. 8974. The Court of Appeals correctly observed that the trial judge conservatively applied a lower zonal valuation for industrial lots, despite higher valuations being available. The determination of zonal valuation involves questions of fact, which are not proper subjects for a petition for certiorari, where the only issue is jurisdiction or grave abuse of discretion. On the fourth issue (Contempt of court): The Supreme Court denied the petition to cite Judge Tac-an in contempt. The Court found that the judge's actions, as explained, did not constitute indirect contempt. The judge's explanation regarding the scheduling and issuance of orders did not show a contumacious disregard for the CA's TRO. Moreover, the issue became moot and academic as Judge Tac-an had compulsorily resigned from the judiciary.
Main Doctrine
An order fixing the fair market value of expropriated lots is interlocutory and not appealable. Appeals must be taken from final judgments or orders that completely dispose of the case. Orders that become final and executory due to lack of appeal must be implemented by the trial court.