City of Cebu v. Dedamo
REITERATIONFacts
The Antecedents: This case stems from an eminent domain proceeding initiated by the City of Cebu against spouses Apolonio and Blasa Dedamo for two parcels of land. The City of Cebu took immediate possession of the property after depositing P51,156.00. Subsequently, the parties entered into a Compromise Agreement, agreeing on a provisional payment of P1,786,400.00, with the final just compensation to be determined by commissioners. The commissioners recommended P20,826,339.50, a figure later adopted by the Regional Trial Court (RTC). Procedural History: The RTC's decision on just compensation was affirmed by the Court of Appeals (CA) and then by the Supreme Court in G.R. No. 142971. After this decision became final and executory, the case was remanded for execution. The RTC issued a writ of execution, and the City of Cebu paid the remaining balance of P19,039,939.50 to the respondent, who had substituted the deceased spouses. The respondent then sought to have the City of Cebu pay 12% legal interest on the unpaid balance from the time of actual taking. The RTC denied this motion, ruling that a final and executory judgment could not be amended to include interest. The CA partially granted the respondent's claim, awarding 12% legal interest from the date the Supreme Court's decision became final until full payment, but rejected the claim for interest from the date of taking. The Petition: This Petition for Review on Certiorari under Rule 45 of the Rules of Court seeks to annul the CA's decision ordering the City of Cebu to pay 12% legal interest on the unpaid balance of just compensation. The petitioner argues that the final judgment in the eminent domain case did not explicitly award interest and therefore cannot be modified. The respondent, however, contends that Section 10, Rule 67 of the Rules of Court mandates the payment of legal interest in such cases, and that this interest should be reckoned from the date of taking, as the unpaid compensation constitutes a forbearance of money.
Issue(s)
Whether the petitioner is barred by res judicata (conclusiveness of judgment) from questioning the award of 12% legal interest. Whether legal interest on just compensation in an eminent domain case should be reckoned from the date of actual taking or from the date of finality of the judgment awarding just compensation.
Ruling
The petition is denied. The Court held that the principle of conclusiveness of judgment bars the petitioner from re-litigating the issue of the 12% legal interest, which was already passed upon and decided in G.R. No. 172942.
Ratio Decidendi
On the issue of res judicata (conclusiveness of judgment): The Court found that the allegations in the present petition were substantially the same as those raised and resolved in G.R. No. 172942. Under the principle of conclusiveness of judgment, a fact or question judicially tried and determined by a court of competent jurisdiction is conclusive upon the parties as long as the judgment remains unreversed. This principle bars the re-litigation of a fact or question already settled in a previous case. Therefore, the petitioner could no longer question the respondent's entitlement to the 12% legal interest awarded by the CA, nor could it re-litigate the reckoning point of such interest, as these matters were bindingly determined in G.R. No. 172942. The relief sought in the present case was inextricably related to the ruling in the prior case, thus invoking the bar of conclusiveness of judgment. On the reckoning point of legal interest: While the Court did not directly rule on this in the present resolution due to res judicata, it acknowledged that the CA had awarded interest from the date of finality of the Supreme Court decision, aligning with the principle that a monetary judgment earns legal interest from finality until satisfaction, as established in Eastern Shipping Lines, Inc. v. Court of Appeals. The respondent's claim for interest from the date of actual taking was rejected by the CA and subsequently by the Supreme Court in G.R. No. 172942, a ruling that became binding on the parties.
Main Doctrine
The principle of conclusiveness of judgment bars the re-litigation of a fact or question already settled in a previous case, even if the relief sought is framed differently, if it is inextricably related to the prior ruling.