Title
Municipality of San Pedro, Laguna vs. Castillo
Case
G.R. No. 45713
Decision Date
Dec 23, 1937
The Philippine government expropriated land from Hacienda de San Pedro Tunasan; San Pedro Municipality intervened, claiming beneficiary rights. The Supreme Court upheld the appointment of appraisal commissioners, ruling that certiorari was unwarranted and intervenors could not delay expropriation.
A

Case Digest (G.R. No. 45713)

Facts:

On December 23, 1937, the Municipality of San Pedro, Laguna filed a petition seeking to set aside an order dated August 31, 1937 issued by Modesto Castillo, Judge of First Instance of Laguna, in civil case No. 6875 for expropriation. The proceedings were instituted by the Government of the Commonwealth of the Philippines under Commonwealth Act No. 20, with Colegio de San Jose and Carlos Young as defendants, for the expropriation of a large parcel included in the Hacienda de San Pedro Tunasan, allegedly occupied by about 1,160 tenants, with a provisional value claimed to be P171,808 and a prayer for authorization of the deposit and immediate delivery of possession “without prejudice” to the appointment of commissioners on appraisal to determine the correct value. Before the defendants submitted their answers, the municipality, as intervenor, filed a complaint in intervention alleging in substance that the hacienda and the portion sought to be expropriated belonged to the Commonwealth Government or, as it alleged, to the Philippine State by right of escheat, and that it was the beneficiary of the entire hacienda and the parcel in question; it also alleged a much lower value of P60,000 and asked, as remedies, for the appointment of Jose H. Guevara as commissioner to represent it, and for delivery and payment to it of any amount fixed as value or indemnity. After the defendants answered and amended, they acknowledged the government’s right to expropriate the portion but asserted substantially higher valuations and damages. In particular, the Colegio de San Jose asserted that it was the registered owner of the entire hacienda and denied any right or interest of the municipality, while Carlos Young asserted that he was the lessee by virtue of a contract with the Colegio. The government stated it had no objection to the court’s determination of adverse rights of the intervenor and the defendants. On March 31, 1937, the trial court denied the Colegio and Carlos Young’s petitions to obtain the P171,808 deposit on the ground that ownership was disputed between the municipality and the Colegio. On August 31, 1937, the respondent judge entered the order appointing commissioners on appraisal: Mariano A. Garcia to represent the government, Fernando Quisumbinor to represent the Colegio and Carlos Young, and Alfonso Farcon as the court’s own choice. The municipality excepted and filed a motion for reconsideration, contending, among others, that the controversy regarding its adverse claims had not been determined and that the commissioner it proposed had not been appointed; the motion was denied, prompting the municipality’s petition for certiorari. The appeal thus questioned whether certiorari lay and whether the trial court could appoint commissioners on appraisal before deciding the municipality’s asserted adverse rights. The petition was denied, with costs to the municipality.

Issues:

Whether the municipality was entitled to certiorari to set aside the August 31, 1937 order appointing commissioners on appraisal in the expropriation case, on the grounds that the trial court lacked jurisdiction, abused its discretion by appointing commissioners despite the unresolved controversy between the municipality and the defendants, and failed to appoint the commissioner proposed by the municipality.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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