National Housing Authority v. Jao
REITERATIONFacts
The Antecedents: On July 28, 1982, the National Housing Authority (NHA) initiated an expropriation proceeding against a 1,660.60 square meter property owned by the late Spouses Ignacio and Andrea Jao Tayag, located in Tondo, Manila. The NHA deposited P66,400.00 as initial compensation and took possession of the property on March 10, 1983, after a writ of possession was issued. The trial court upheld the NHA's right to expropriate and canceled the original title, issuing a new one in the NHA's name. However, for over fifteen years, the NHA failed to develop the property for any public purpose, leaving it to deteriorate and become occupied by squatters, and crucially, failed to pay the just compensation to the Spouses Jao Tayag. Procedural History: On May 20, 1997, Perico V. Jao, representing the estate of the Spouses Jao Tayag, filed a case for recovery of possession and damages against the NHA. The Regional Trial Court (RTC) ruled in favor of Jao on September 4, 1998, ordering the NHA to reconvey the property, pay P10,000.00 monthly for the loss of use and occupancy, P500,000.00 for damages to improvements, and P20,000.00 for attorney's fees. The NHA's motion for reconsideration was denied. The NHA appealed to the Court of Appeals (CA), but the appeal was dismissed on February 11, 2000, for failure to pay docket fees, and this dismissal became final and executory on March 9, 2000. Subsequently, Jao sought a writ of execution, which the RTC granted. The NHA filed a motion to quash the writ, arguing that damages should be limited to the initial deposit, but the RTC denied this motion. The NHA then filed a petition for certiorari with the CA, which was dismissed on July 16, 2002, for essentially being an appeal of a final and executory decision. The CA denied the NHA's motion for reconsideration on January 10, 2003. The Petition: The National Housing Authority filed this petition for review under Rule 45 of the Rules of Court, assailing the Court of Appeals' Decision and Resolution. The NHA argued that the CA erred in holding that its petition was in the nature of an appeal and that the RTC did not commit grave abuse of discretion. The core of the NHA's argument was that any damages awarded should have been limited to the initial P66,400.00 deposit made for the expropriation. The NHA sought to overturn the final and executory orders of the lower courts which mandated reconveyance of the property and substantial monetary awards for damages and lost use.
Issue(s)
Whether the Court of Appeals erred in holding that the NHA's petition for certiorari was in the nature of an appeal. Whether the trial court committed grave abuse of discretion in denying the NHA's motion to quash the writ of execution and notice of garnishment.
Ruling
The Supreme Court denied the petition, affirming the decision of the Court of Appeals. The Court held that the trial court's order for reconveyance and damages had become final and executory and could no longer be disturbed. The Court emphasized that any judicial error should have been corrected through an appeal, not through subsequent actions seeking to amend a final judgment.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in holding that the NHA's petition for certiorari was in the nature of an appeal: The Supreme Court affirmed the Court of Appeals' finding. The Court reiterated that the NHA's petition for certiorari sought to set aside orders that were corollary consequences of a final and executory judgment. By seeking to revisit the merits of the case through a petition for certiorari, the NHA was essentially attempting to appeal a decision that had already attained finality. The Court emphasized that a final and executory order can no longer be disturbed, and any judicial error should have been corrected through a timely appeal. Allowing the NHA to attack the merits of the case at this juncture would transgress settled rules and jurisprudence regarding finality of judgments. The Court noted that the NHA's appeal to the Court of Appeals was dismissed for failure to pay docket fees, and this dismissal became final and executory. On the issue of whether the trial court committed grave abuse of discretion in denying the NHA's motion to quash the writ of execution and notice of garnishment: The Supreme Court found no grave abuse of discretion on the part of the trial court. The trial court correctly relied on Rule 67, Section 11 of the Rules of Court, which allows for the enforcement of restoration of possession and determination of damages when an expropriation proceeding is not consummated. The trial court's original decision, which ordered the reconveyance of the property and payment of damages, had become final and executory. Therefore, the writ of execution was a necessary corollary to enforce this final judgment. The trial court correctly reasoned that the preliminary deposit for expropriation does not serve as a limitation on the amount of damages recoverable by the landowner. Citing established jurisprudence, the trial court highlighted that landowners are entitled to recover all damages occasioned by the institution of the expropriation action, including loss of use and occupation, expenses, and destruction of improvements, without limitation to the initial deposit. The trial court's denial of the motion to quash was a proper enforcement of a final and executory judgment.
Main Doctrine
A final and executory order, even if erroneous, cannot be disturbed and must be enforced. Any judicial error should be corrected through an appeal, not through subsequent actions that seek to amend the judgment.