National Power Corporation v. Posada
REITERATIONFacts
The Antecedents: The National Power Corporation (NPC) initiated expropriation proceedings to acquire a right-of-way easement, and later portions, of land in Catanduanes for its Substation Island Grid Project. The respondents, landowners, objected to NPC's initial offer of P500.00 per square meter, asserting the property's value was P2,000.00 per square meter. The trial court initially confirmed NPC's right to expropriate and appointed commissioners to determine just compensation. The commissioners recommended P1,500.00 per square meter, considering the land's location, potential for residential and business use, and the presence of structures. Procedural History: The Regional Trial Court (RTC) ordered the creation of a commission to determine just compensation. NPC filed a Notice to Take Possession based on a deposit of P3,280.00. After the commissioners recommended P1,500.00 per square meter, NPC opposed, arguing the valuation was speculative. NPC later amended its complaint to acquire portions of the property, depositing P580,769.93. The RTC issued a Writ of Possession, but later recalled it due to NPC's failure to deposit an additional P262,639.17 for structures and improvements, and fixed just compensation at P2,000.00 per square meter. The Court of Appeals affirmed the RTC's decision, including the recall of the Writ of Possession. NPC then filed a Petition for Review with the Supreme Court. The Petition: The National Power Corporation filed a Petition for Review on Certiorari seeking to reverse the Court of Appeals' decision. NPC argued that the P2,000.00 per square meter just compensation was excessive, that the commissioners' valuation was speculative, and that the Writ of Possession should not have been recalled as it had made the required provisional deposit under Republic Act No. 8974. Subsequently, NPC filed a Motion to Withdraw its Petition, stating it no longer needed the properties as it was acquiring an alternative site. The core issue before the Supreme Court became whether NPC could withdraw its petition and if such withdrawal would dismiss its expropriation complaint.
Issue(s)
Whether the National Power Corporation may be allowed to withdraw its Petition for Review, considering the purpose for which the property was taken no longer exists. Whether the withdrawal of the Petition for Review has the effect of dismissing its Amended Complaint before the trial court, and the implications for potential prejudice to the respondents.
Ruling
The Supreme Court granted the Motion to Withdraw the Petition for Review. However, it remanded the case to the Regional Trial Court of Virac, Catanduanes, Branch 43 for appropriate action, stating that the withdrawal of the Petition before the Supreme Court would have no practical effect other than to make the trial court's order of condemnation final and executory. The trial court must determine whether the respondents have already been prejudiced by the expropriation. The National Power Corporation must file the proper Motion to Withdraw before the trial court and plead and prove its reasons for discontinuing the expropriation, while respondents may plead and prove damages incurred.
Ratio Decidendi
On the withdrawal of the Petition for Review: The Supreme Court granted the National Power Corporation's Motion to Withdraw its Petition for Review. The Court reiterated that expropriation proceedings are governed by Rule 67 of the Rules of Court and Republic Act No. 8974. The power of eminent domain is inherent in the state but is subject to limitations, primarily public use and just compensation. When the purpose for which private property is taken ceases to exist, the expropriation proceeding may no longer continue. The Court cited National Housing Authority v. Heirs of Guivelondo and Metropolitan Water District v. De Los Angeles, which held that expropriation actions must be dismissed if it is made to appear that the expropriation is no longer for a public use, even during the pendency of an appeal. Since the National Power Corporation was no longer using the respondents' properties for the intended Substation Project, it could be allowed to discontinue the proceedings, subject to judicial discretion. On the effect of withdrawal on the Amended Complaint: The Supreme Court clarified that the withdrawal of the Petition for Review before it does not automatically dismiss the Amended Complaint before the trial court. The Court distinguished between dismissing an action at the plaintiff's instance during its pendency and the effect of withdrawing an appeal after a judgment has become final and executory. In National Housing Authority v. Heirs of Guivelondo, it was held that if the trial court's order of condemnation becomes final and executory, and the government has already taken possession and caused prejudice to the landowner, the expropriation case is not automatically dismissed. The Court noted that in this case, respondents had not yet been deprived of their property as NPC never took possession, and prejudice could not be determined. Therefore, the case was remanded to the trial court to determine if respondents suffered prejudice, and for NPC to file a proper motion to withdraw its complaint there, allowing respondents to prove any damages incurred.
Main Doctrine
The National Power Corporation's Motion to Withdraw its Petition for Review is granted, but the case is remanded to the trial court to determine prejudice to the respondents, as the withdrawal of the petition does not automatically dismiss the expropriation complaint if the order of condemnation has become final and executory or if the government has taken possession and caused prejudice to the landowner.