Republic v. Legaspi
REITERATIONFacts
1. The Antecedents: In December 1978, Rosalina Libo-on sold a 40,133-square meter property to the University of the Philippines (UP) for P56,479.50. UP took possession and began constructing facilities. However, in January 1980, Rosalina rescinded the sale, claiming she had previously conveyed the property via barter to several individuals, including the respondents. These respondents subsequently subdivided the lot and obtained new titles. UP filed an eminent domain case in 1991, alleging the property was within its campus and that negotiations for its retention had failed. UP sought to expropriate the property for public use and determine just compensation. 2. Procedural History: The Regional Trial Court (RTC) initially granted UP's motion to continue possession upon deposit of P50,070.00. In 1992, the RTC issued an order of condemnation for three lots (Lot Nos. 21609-B, 21609-C, and 21609-E) totaling 8,516 square meters, after respondents limited their opposition to these parcels. The RTC later fixed the just compensation for these three lots at P51,096.00. In 2003, the RTC issued an order upholding UP's right to expropriate the remaining seven lots but excluded the area occupied by the Villa Marina Beach Resort. Upon reconsideration, the RTC, in 2004, denied the expropriation of these seven lots entirely, finding that their exclusion would not affect UP's operations and citing reasons such as private business use and respect for tradition regarding a public cemetery. The Republic, through UP, then filed a petition for certiorari with the Court of Appeals (CA), assailing the RTC's orders. 3. The Petition: The Court of Appeals denied the Republic's petition for certiorari, ruling that the proper remedy from the RTC's orders was an ordinary appeal, not a petition for certiorari, as the orders were final and appealable. The Republic then filed a petition for review on certiorari with the Supreme Court, arguing that the CA erred in denying the petition and affirming the RTC's order, particularly the order of May 31, 2004, which allegedly failed to state the facts and law on which it was based. The Supreme Court found merit in the petition, holding that the CA overlooked the possibility of certiorari in cases of grave abuse of discretion and that the RTC committed grave abuse of discretion by issuing orders that lacked factual and legal bases and disregarded evidence on record, particularly in denying the expropriation of the remaining seven lots.
Issue(s)
Whether the Court of Appeals erred in denying the petition for certiorari on the ground that the proper remedy was an ordinary appeal. Whether the Regional Trial Court committed grave abuse of discretion in issuing the orders dated November 17, 2003, and May 31, 2004, denying the expropriation of the remaining seven lots.
Ruling
The Supreme Court reversed and set aside the Court of Appeals' decision. It declared the RTC's orders dated November 17, 2003, and May 31, 2004, null and void, and directed the RTC to resolve the case in compliance with Section 14, Article VIII of the Constitution and in accordance with the evidence on record.
Ratio Decidendi
On the propriety of the remedy (Certiorari vs. Appeal): The Court held that while ordinarily, an appeal is the proper remedy from a final order of condemnation or denial of expropriation, the rigid application of this rule may be relaxed when it results in a manifest failure of justice or when public welfare is involved. The Court found that the RTC's actions constituted grave abuse of discretion, making certiorari an appropriate remedy to correct such errors, especially when the ordinary appeal might not be speedy or adequate enough to address the injurious effects of the RTC's orders. The Court cited jurisprudence where certiorari was allowed in lieu of appeal to prevent a miscarriage of justice, particularly in cases involving public interest. On the RTC's grave abuse of discretion: The Court found that the RTC committed grave abuse of discretion in issuing the assailed orders. Firstly, the November 17, 2003 order excluded the Villa Marina Beach Resort area without stating any factual or legal basis, violating the constitutional mandate to clearly and distinctly state the facts and law on which decisions are based. Secondly, the May 31, 2004 order, which denied expropriation of the remaining seven lots, disregarded the evidence on record. The Court noted that the private use of the lots by respondents for businesses or residences is not a valid reason to deny expropriation if the taking is for a public purpose and just compensation is paid. Furthermore, the RTC's conclusion that excluding these lots would not adversely affect UPV's operations was unsubstantiated and contradicted evidence suggesting the area was earmarked for UPV's development plans. The Court also found no basis for the RTC's claim that UPV had previously excluded the resort area from its expropriation efforts.
Main Doctrine
A Rule 65 petition for certiorari may be allowed to correct grave abuse of discretion by the trial court in denying expropriation, even if an appeal was the proper remedy, especially when rigid application of the rule would result in a miscarriage of justice or when public welfare is involved. Orders of condemnation and denial of expropriation are final and appealable, but certiorari may be availed of if the denial constitutes grave abuse of discretion.