Republic v. Heirs of Lacsina
REITERATIONFacts
The Antecedents: The Republic of the Philippines, represented by the DPWH-NCR, filed a complaint for expropriation of three parcels of land owned by the Heirs of Isabel D. Lacsina, Cabever Realty Corporation (Cabever), and St. Ignatius of Loyola School (SILS) for the completion of the Taguig Diversion Road. Respondents did not contest the right to expropriate but objected to the provisional valuation. The Heirs of Lacsina claimed a higher market value, Cabever asserted a higher fair market value and prayed for consequential damages due to the division of its property, and SILS claimed its property was for campus expansion and sought compensation for its intended use and consequential damages. Procedural History: The RTC issued an Order of Expropriation. A board of commissioners was formed, recommending P10,000.00 per square meter for the properties and P5,000.00 per square meter for consequential damages to Cabever and SILS. The RTC, in its Decision dated February 18, 2015, fixed just compensation at P15,000.00 per sq. m. for all properties, finding consequential benefits exceeded damages, and denied consequential damages. The Republic appealed to the CA, arguing the RTC failed to determine proper just compensation. The CA, in its Decision dated October 18, 2018, modified the RTC ruling by setting just compensation at P10,000.00 per sq. m. and awarded consequential damages of P5,000.00 per sq. m. to Cabever and SILS. The CA also ruled on legal interest. The Republic moved for partial reconsideration to delete the consequential damages, which the CA denied. The Republic then filed a Petition for Review on Certiorari before the Supreme Court. The Petition: The Republic assails the CA's Decision and Resolution, arguing that the CA exceeded its jurisdiction by awarding consequential damages when respondents Cabever and SILS did not appeal the RTC's denial of such damages, and that Cabever and SILS are not entitled to consequential damages.
Issue(s)
Whether the CA erred in awarding consequential damages in favor of Cabever and SILS despite the fact that they did not appeal from the RTC Decision denying such award. Assuming that the CA can pass upon the issue on consequential damages, whether Cabever and SILS are entitled to the payment of consequential damages for the unaffected portions of their respective properties.
Ruling
The Court grants the petition. The Decision dated October 18, 2018, and the Resolution dated March 21, 2019, of the Court of Appeals are affirmed with modification, deleting the award of consequential damages in favor of Cabever Realty Corporation and St. Ignatius of Loyola School.
Ratio Decidendi
On the issue of whether the CA erred in awarding consequential damages despite the lack of appeal by the appellees: The Court ruled in the affirmative. The well-settled rule is that a decision becomes final as against a party who does not appeal it. An appellee who has not himself appealed cannot obtain from the appellate court any affirmative relief other than those granted in the decision of the court below. In this case, Cabever and SILS did not appeal the RTC Decision which denied their claim for consequential damages. Their respective Briefs for the Defendant-Appellee before the CA prayed for the affirmation of the RTC Decision, save for the payment of interest. Therefore, as far as Cabever and SILS were concerned, the issue on consequential damages had become final and executory. The CA erred in awarding consequential damages to them, as this would grant them affirmative relief they did not seek through their own appeal. On the issue of whether Cabever and SILS are entitled to the payment of consequential damages for the unaffected portions of their respective properties: The Court clarified that the exceptions under Section 8, Rule 51 of the Rules of Court, which allow the appellate court to pass upon plain errors and clerical errors, or issues closely related to or dependent on an assigned error, are for the benefit of the appellant and not for the appellee. Here, the CA's disposition effectively applied these exceptions in favor of Cabever and SILS, who were appellees before the CA. This is contrary to established jurisprudence. Even if the issue of consequential damages to the remaining lots were considered closely related to the issue of just compensation for the expropriated lots, the exceptions could not be invoked to grant affirmative relief to the appellees. Thus, the CA's award of consequential damages was erroneous on this ground as well.
Main Doctrine
An appellee who has not himself appealed cannot obtain from the appellate court any affirmative relief other than those granted in the decision of the court below. Furthermore, the exceptions under Section 8, Rule 51 of the Rules of Court can only be applied for the benefit of the appellant and not for the appellee.