National Power Corp. v. Tarcelo
REITERATIONFacts
The Antecedents: Respondents Felicisimo Tarcelo and the heirs of Comia Santos owned two lots in Batangas City. Petitioner National Power Corporation (NPC) filed a case to expropriate portions of these lots (totaling 1,595.91 square meters) for its natural gas pipeline project. Procedural History: The Regional Trial Court (RTC) of Batangas City fixed just compensation at ₱1,000.00 per square meter. NPC appealed, and the Court of Appeals (CA) modified the decision, lowering the just compensation to ₱797.50 per square meter but affirming the principle that respondents were entitled to full market value for the affected property, not just an easement fee. The CA's decision became final and executory. Respondents moved for execution, and a writ was issued for ₱5,594,462.50, representing compensation for the entire lots (7,015 square meters), not just the affected portions. NPC filed an Urgent Omnibus Motion to quash the writ, arguing it was inconsistent with the decisions which only pertained to the affected areas. The RTC denied NPC's motion, reasoning that the nature of underground pipelines imposed more burdensome restrictions than transmission lines, potentially rendering the entire property useless and citing precedent where entire properties were compensated. NPC's motion for reconsideration was denied for lack of notice of hearing. NPC then filed a Petition for Certiorari with the CA, which was denied. NPC filed a Motion for Reconsideration, which was also denied. The Petition: NPC sought to set aside the CA's decision and resolution, as well as the RTC's orders and the writ of execution and notice of garnishment, arguing that the execution demanded payment for the entire property instead of only the affected portions, contrary to the original complaint and decisions.
Issue(s)
Whether the Court of Appeals erred in upholding the trial court's orders approving the notice of garnishment which demanded payment of just compensation for the entire property of respondents instead of the affected portions only, in accordance with the complaint and the trial court's decision. Whether the Court of Appeals erred in upholding the order of the trial court which denied petitioner's motion for reconsideration in complete disregard of liberality enunciated in several decisions of the Supreme Court.
Ruling
The Petition is GRANTED. The January 20, 2011 Decision and August 9, 2011 Resolution of the Court of Appeals in CA-G.R. SP No. 112054 are PARTIALLY REVERSED and SET ASIDE. The September 24, 2009 and October 23, 2009 Orders of the Regional Trial Court of Batangas City, Branch VII in Civil Case No. 5785 are declared NULL and VOID IN PART, specifically the Notice of Garnishment which is nullified and set aside. Petitioner National Power Corporation is adjudged liable to pay just compensation to respondents for the affected portions of their respective properties totaling 1,595.91 square meters, at ₱797.50 per square meter, subject to interest. Petitioner is also directed to pay the Commissioners' Fees.
Ratio Decidendi
On the Issue of Payment for Affected Portions vs. Entire Property: The Supreme Court ruled that the dispositive portion of the trial court's November 7, 2005 Decision, as affirmed by the CA, clearly indicated that NPC was to acquire an easement of right-of-way over the affected portions of the properties upon payment of just compensation. The Commissioners' Reports also specifically recommended compensation for the affected areas only. The Court emphasized that the dispositive portion of a decision is the controlling part for execution, and any writ of execution must conform strictly to it. The Notice of Garnishment, which demanded payment for the entire 7,015 square meters, varied the tenor of the judgment and thus was declared null and void. The Court found that both the trial and appellate courts erred in upholding the execution for the entire property, as the original expropriation sought only specific portions for the pipeline. On the Denial of NPC's Motion for Reconsideration: The Supreme Court found the issue of NPC's failure to include a notice of hearing in its motion for reconsideration to be rendered irrelevant by its pronouncement that the RTC's September 24, 2009 Order, in relation to the Notice of Garnishment, was null and void. The Court reiterated that a void judgment or order has no legal effect and may be ignored. Therefore, the denial of the motion for reconsideration due to a technicality was superseded by the fundamental flaw in the order it sought to reconsider concerning the scope of execution.
Main Doctrine
The dispositive portion of a decision controls its execution, and any writ of execution must conform strictly to what is ordained therein. If a writ of execution varies the tenor of the judgment or exceeds its terms, it is considered a nullity.