Case Digest (G.R. No. 132431)
Facts:
The consolidated petition involves the Estate or Heirs of the Late Ex-Justice Jose B. L. Reyes, represented by Adoracion D. Reyes, and the Estate or Heirs of the Late Dr. Edmundo A. Reyes, represented by Maria Teresa P. Reyes and Carlos P. Reyes (collectively “petitioners”), against the City of Manila and, in a related certiorari proceeding, the Court of Appeals, Dr. Rosario Abiog, Angelina Maglonso and Sampaguita Bisig ng Magkakapitbahay, Inc. (“respondents”). Petitioners are pro indiviso co-owners of 11 parcels of land in Sta. Cruz, Manila, which they sought to recover by ejectment suits beginning in November 1993 and May 1994. While ejectment judgments became final and executory in 1998, the City filed an eminent domain complaint in April 1995 under Ordinance No. 7818 to distribute the parcels to long-term occupants as socialized housing beneficiaries. The Regional Trial Court dismissed the City’s complaint for failure to prove both a valid offer and public purpose, promptingCase Digest (G.R. No. 132431)
Facts:
- Parties and properties
- Petitioners are the Estate or heirs of the late Justice Jose B.L. Reyes and of Dr. Edmundo A. Reyes, pro indiviso co-owners of 11 parcels (13,940 sqm) in Sta. Cruz, Manila (TCT No. 24359).
- Respondents include the City of Manila (which filed expropriation proceedings) and various occupants/lessees—Dr. Rosario Abiog, Angelina Maglonso, and Sampaguita Bisig ng Magkakapitbahay, Inc. (SBMI).
- Ejectment proceedings
- In November 1993 and May 1994, petitioners filed ejectment complaints against Abiog and Maglonso before the Metropolitan Trial Court (MTC) of Manila.
- The MTC rendered decisions in favor of petitioners (May 9, 1994 and May 4, 1995); the RTC and the Court of Appeals denied respondents’ appeals. The eviction judgments became final and executory in 1998, and writs of execution issued.
- Expropriation proceedings
- On April 25, 1995, the City of Manila, under Ordinance No. 7818 (authorizing expropriation of ~9,930 sqm for socialized housing beneficiaries: occupants of at least 10 years), filed a complaint for eminent domain before the RTC, Branch 9.
- The City alleged it made a written offer of ₱10,285,293.38 (rejected by petitioners) and deposited ₱1,452,657 (15% provisional deposit). SBMI moved to intervene and for injunction; the trial court denied intervention and, on October 3, 1995, dismissed the complaint for expropriation.
- Appeals and petitions
- The City appealed to the Court of Appeals (CA). On January 27, 1998, the CA reversed the RTC, ordered condemnation, and remanded for determination of just compensation.
- Petitioners filed:
- A petition for review under Rule 45 (G.R. No. 132431) challenging the CA’s expropriation ruling.
- A petition for certiorari under Rule 65 (G.R. No. 137146) assailing two CA resolutions (Aug. 19 and Dec. 16, 1998) that issued protective orders enjoining enforcement of the final eviction judgments.
Issues:
- Issues on the expropriation (G.R. No. 132431)
- Did the City comply with Sections 9 and 10 of Republic Act No. 7279 (Urban Development and Housing Act of 1992) regarding priorities and modes of land acquisition?
- Is Ordinance No. 7818 unconstitutional under the Equal Protection Clause or as impairing contracts?
- Was there a valid and definite offer to purchase, and was the 15% deposit sufficient?
- Were petitioners in fact unwilling to sell, and did the CA err in not pronouncing just compensation?
- Issues on the protective orders (G.R. No. 137146)
- Did the Court of Appeals have jurisdiction to issue protective orders enjoining execution of final eviction judgments pending Supreme Court resolution?
- Did the CA commit grave abuse of discretion in allowing SBMI and occupants to intervene and obtain injunctive relief?
- Are the so-called protective orders effectively injunctions in disguise, contrary to procedural rules?
- Did respondents engage in forum-shopping by seeking relief in CA after final denial of intervention by the RTC?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)