Case Digest (G.R. No. 108015)
Facts:
Cristina de Knecht and Rene Knecht, Petitioners, v. Court of Appeals et al., G.R. Nos. 108015 and 109234, May 20, 1998, Second Division, Puno, J., writing for the Court.The Knechts owned an 8,102.68 sq. m. parcel at the corner of E. de los Santos Avenue (EDSA) and F.B. Harrison, Pasay City, covered by TCT No. 9032 and improved with eight houses. In 1979 the Republic filed Civil Case No. 7001‑P for expropriation; this Court in De Knecht v. Bautista (G.R. No. L‑51078) annulled the writ of possession and enjoined the trial court on grounds that the chosen area for EDSA extension was arbitrary.
In 1982 the City Treasurer sold the property at a tax delinquency auction for unpaid 1980–1982 taxes; respondents Spouses Anastacio and Felisa Babiera and Spouses Alejandro and Flor Sangalang were the highest bidders. The Knechts failed to redeem within a year. The Babieras and Sangalangs filed land registration petitions (LRC Cases Nos. 2636‑P and 2652‑P) and the Register of Deeds cancelled TCT No. 9032 and issued TCT No. 86670 in the buyers’ names. In March 1985 the buyers sold the land to Salem Investment Corporation (Salem) (TCT No. 94059).
While the government later enacted B.P. Blg. 340 (1983) authorizing expropriation of specified Pasay properties for EDSA extension and flood control, the Knechts separately filed Civil Case No. 2961‑P (June 24, 1985) for reconveyance and annulment of the tax sale and titles, alleging lack of notice. Salem obtained a receivership in the reconveyance case; the trial court dismissed the Knechts’ reconveyance case on September 13, 1988 for apparent lack of interest (failure to appear) and ordered further proceedings on the defendants’ counterclaim. The Knechts’ motions for reconsideration and petitions to the Court of Appeals and this Court were denied, and final judgment was entered in February 1990.
On May 15, 1990 the Republic, through the Solicitor General, filed Civil Case No. 7327 in the Regional Trial Court, Branch 111 (Pasay) “for determination of just compensation” under B.P. Blg. 340; the trial court issued a writ of possession (Aug. 29, 1990) and partial payment orders releasing funds to Salem and, later, to Mariano Nocom (who purchased a portion from Salem). Seven of the Knechts’ houses were demolished Aug. 30, 1990; their last house was demolished April 6, 1991 after an unlawful detainer action by Salem.
After various interim orders for release of funds, the Knechts filed (Sept. 25, 1991) a “Motion for Intervention and to Implead Additional Parties” in Civil Case No. 7327 and a motion to inhibit Judge Sayo and to consolidate their other case. The trial court denied the intervention (Apr. 14, 1992) and declared the inhibition/consolidation motion moot; the court proceeded to fix compensation and ordered releases to Salem and Nocom.
The Knechts filed two original actions in the Court of Appeals: CA‑G.R. SP No. 28089 (annulment of various judgments and reliefs including ...(Pro-only)
Issues:
- Was the Knechts’ challenge barred by res judicata because Civil Case No. 2961‑P was dismissed with prejudice and became final?
- Did the Knechts have a legal interest or right to intervene in Civil Case No. 7327 and thereby to claim a share of just compensation as occupants?
- Was Civil Case No. 7327 an expropriation proceeding governed by Rule 67 such that occupants/claimants should have...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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