Title
Bautista vs. Yujuico
Case
G.R. No. 199654
Decision Date
Oct 3, 2018
City of Manila expropriated Teresita Yujuico's property for a school. Garnishment of funds led to contempt charges against Land Bank manager Isidro Bautista, who refused release citing legal instructions. SC ruled Isidro acted in good faith, dismissing contempt charges.
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Case Digest (G.R. No. 199654)

Facts:

Background of the Case

This case arose from a complaint for expropriation filed by the City of Manila against respondent Teresita M. Yujuico (Teresita), the registered owner of a property with an area of 3,979.10 square meters. The City of Manila intended to use the property for the construction of the Francisco Benitez Elementary School. The RTC granted the expropriation and fixed the fair market value of the property at Php 18,164.80 per square meter, with improvements valued at Php 978,000.00. The total just compensation amounted to Php 73,257,555.00, minus Php 5,363,289.00 already deposited, leaving a balance of Php 67,894,266.00.

Execution of Judgment

The judgment became final and executory, and a Writ of Execution was issued. The sheriff served a Notice of Garnishment on the funds of the City of Manila in the Land Bank of the Philippines, YMCA Branch. The City of Manila moved to quash the garnishment, but the RTC denied the motion, directing the release of Php 31,039,881.00 from the Land Bank.

Non-Compliance and Mandamus Petition

Teresita filed a petition for mandamus to compel the City School Board (CSB) to pass a resolution appropriating the remaining balance. The RTC granted the mandamus, but the CSB filed a petition for relief from judgment, which was eventually denied by the Supreme Court.

Garnishment and Contempt Proceedings

Teresita moved for the execution of the judgment, and the RTC issued an order directing the Land Bank to release the funds. However, Isidro A. Bautista (Isidro), the Branch Manager of Land Bank, YMCA Branch, refused to comply, citing instructions from the City Legal Office and the bank's Litigation Department. Teresita filed a petition for indirect contempt against Isidro, which the RTC granted, finding him guilty and imposing a fine of Php 30,000.00.

Subsequent Compliance

Isidro eventually released the funds after the City Treasurer of Manila authorized the payment. He argued that the contempt proceedings were rendered moot by his compliance.

Issue:

  1. Whether the Court of Appeals (CA) erred in affirming the RTC's decision finding Isidro liable for indirect contempt.
  2. Whether Isidro's subsequent compliance with the court's order rendered the contempt proceedings moot and academic.

Ruling:

The Supreme Court granted the petition and reversed the CA's decision. The Court held that Isidro was not guilty of indirect contempt. His refusal to release the funds was justified based on the instructions from the City Legal Office and the bank's Litigation Department. The Court emphasized that Isidro acted in good faith and did not willfully disobey the court's order.

Ratio:

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