Apo Fruits Corp. v. Land Bank
REITERATIONFacts
The Antecedents: Petitioners Apo Fruits Corporation (AFC) and Hijo Plantation, Inc. (HPI) voluntarily offered to sell their lands under Republic Act No. 6657. Land Bank of the Philippines (Land Bank) initially valued the properties, but the valuation was rejected. Land Bank deposited sums representing its valuation, which petitioners withdrew. Petitioners later filed complaints for determination of just compensation with the DAR Adjudication Board (DARAB), and upon its inaction, with the Regional Trial Court (RTC) acting as a Special Agrarian Court (SAC). Procedural History: The RTC fixed the just compensation at P1,383,179,000.00 and ordered payment of interest, commissioners' fees, and attorney's fees. Upon Land Bank's motion, the RTC modified its decision, specifying 12% interest per annum from filing until finality and thereafter, and retaining commissioners' and attorney's fees. Land Bank appealed to the Court of Appeals (CA) via notice of appeal, but the RTC denied due course, citing the ruling in Land Bank of the Philippines v. De Leon that a petition for review under Rule 43 was the proper mode. The CA granted Land Bank's petition for certiorari, nullifying the RTC's orders. The Supreme Court's Third Division affirmed the CA's decision giving due course to Land Bank's appeal and also affirmed the RTC's decision on the merits regarding just compensation. On Land Bank's motion for reconsideration, the Third Division deleted the award of 12% interest and attorney's fees, and remanded the case for further hearing on commissioners' fees. Entry of judgment was issued. AFC and HPI filed a second motion for reconsideration, which was denied. The case was then referred to the Court en banc. The Petition: AFC and HPI filed a second motion for reconsideration, seeking to reinstate the award of legal interest and attorney's fees, and a motion to refer the matter to the Court en banc. They argued that the deletion of interest and attorney's fees was contrary to established jurisprudence, and that interest should be awarded from the date of taking or, alternatively, from the filing of the complaint, and that they were entitled to attorney's fees.
Issue(s)
Whether the second motion for reconsideration, seeking to reinstate awards for legal interest and attorney's fees, should be granted despite the finality of the judgment. Whether petitioners are entitled to legal interest on the just compensation awarded. Whether petitioners are entitled to attorney's fees.
Ruling
The Court denied the second motion for reconsideration filed by Apo Fruits Corporation (AFC) and Hijo Plantation, Inc. (HPI) with respect to the denial of the award of legal interest and attorney's fees. The Court reiterated its decision dated February 6, 2007, and its resolution dated December 19, 2007, of the Third Division. The Court held that granting the motion would violate the doctrine of immutability of a final judgment and that the award of interest and attorney's fees was unwarranted as Land Bank did not incur undue delay in payment.
Ratio Decidendi
On the issue of immutability of judgment: The Court emphasized the long-established doctrine of immutability of judgments, stating that once a judgment has acquired finality, it becomes immutable and unalterable, even by the highest court. This doctrine serves the dual purpose of avoiding undue delay in the administration of justice and putting an end to judicial controversies. The Court found that the second motion for reconsideration sought to reopen a final and executory judgment, which is not permissible unless the case falls under recognized exceptions such as clerical errors, nunc pro tunc entries, void judgments, or supervening circumstances rendering execution unjust. None of these exceptions applied to the petitioners' private claim for interest and attorney's fees, which did not involve substantial, transcendental, or paramount public interest issues. On the entitlement to legal interest: The Court reiterated that interest on just compensation is awarded only in case of delay in payment, as provided by Article 2209 of the Civil Code. The history of the case demonstrated that Land Bank did not incur undue delay. After petitioners rejected the initial valuation, Land Bank opened deposit accounts and credited the amounts, which petitioners withdrew. Although petitioners filed complaints, any delay in the resolution was not solely attributable to Land Bank, as assailing an erroneous order before a higher court is a legal remedy. The Court cited Land Bank of the Philippines v. Kumassie Plantation to support the principle that appealing decisions does not automatically constitute deliberate delay warranting interest. On the entitlement to attorney's fees: The Court affirmed the deletion of the award of attorney's fees. It noted that the Regional Trial Court (RTC) failed to substantiate its award of attorney's fees, which amounted to ten percent (10%) of the determined just compensation. The general rule is that attorney's fees cannot be recovered as part of damages unless exceptional circumstances exist, and the RTC's decision did not provide the necessary factual and legal justification for such an award. The Third Division's deletion was based on the lack of substantiation, and this reasoning was maintained by the en banc Court.
Main Doctrine
The Supreme Court, sitting en banc, denied a second motion for reconsideration seeking to reinstate awards for legal interest and attorney's fees, upholding the immutability of a final judgment. The Court reiterated that interest on just compensation is only awarded if there is proven delay in payment by the government, and in this case, Land Bank's actions did not constitute undue delay, thus negating the claim for interest and attorney's fees.