Case Digest (G.R. No. 77029)
Facts:
In 1978, National Power Corporation (NPC), the petitioner, entered into possession of a 21,995‐square‐meter parcel of land in Marawi City (the subject land) to construct the Agus I hydroelectric plant under Proclamation No. 1354 (1974), believing it to be public land. The property, however, was registered as private land under Transfer Certificate of Title No. 378‐A in the name of Macapanton K. Mangondato. Mangondato first learned of NPC’s occupation in 1979 and, by letter dated September 28, 1981, demanded compensation, detailing his hereditary title. NPC initially denied his claim, but by the early 1990s conceded Mangondato’s ownership and tried to negotiate just compensation. Failing agreement, Mangondato filed Civil Case No. 605‐92 for reconveyance and rentals, while NPC filed Civil Case No. 610‐92 for expropriation. The RTC of Marawi City consolidated both cases and, on August 21, 1992, denied reconveyance, condemned the land for NPC’s benefit, and awarded Mangondato just cCase Digest (G.R. No. 77029)
Facts:
- Occupation and Title Dispute
- In 1978, National Power Corporation (NPC) took possession of a 21,995 sqm parcel in Marawi City for its Agus 1 hydroelectric project, believing it was public land reserved by Proclamation No. 1354 (1974).
- The land was privately titled under TCT No. 378-A in the name of Macapanton K. Mangondato. In 1979 Mangondato discovered NPC’s occupation and in 1981 formally demanded compensation, tracing his ancestral ownership and subdivisions.
- Pre-litigation Efforts and RTC Proceedings
- Early 1990s, after failed negotiations on fair compensation, Mangondato filed a reconveyance suit (Civil Case No. 605-92) and NPC filed an expropriation suit (610-92); both were consolidated before RTC Branch 8.
- On 21 August 1992, the RTC: denied reconveyance, condemned the land in NPC’s favor effective July 1992; awarded just compensation of ₱21,995,000; and ordered NPC to pay rentals of ₱15,000/mo from 1978–1992 with 12% per annum interest.
- Appellate History and Execution
- NPC appealed to the Court of Appeals (CA CV 39353); CA affirmed. NPC petitioned the Supreme Court (G.R. 113194); on 11 March 1996 the Court upheld CA but reduced rental interest to 6%. Decision became final on 13 May 1996.
- Mangondato moved to execute; despite NPC’s opposition citing a TRO in a separate suit, RTC Branch 8 issued a writ of execution (4 June 1996) and garnished NPC’s bank accounts for ₱21,801,951, which was paid to Mangondato.
- Civil Case No. 967-93 by Heirs
- On 29 March 1993, Lucman M. Ibrahim and heirs of Datu Magayo-ong Maruhom filed Civil Case No. 967-93 against Mangondato and NPC, disputing Mangondato’s title and claiming heirship; they obtained a TRO and preliminary injunction against NPC’s payment to Mangondato.
- On 16 April 1998, RTC Branch 10 found Ibrahims and Maruhoms to be true owners; held that expropriation precluded reconveyance; and ordered Mangondato and NPC jointly liable for rentals, indemnity (₱21,801,051) and ₱200,000 attorney’s fees. Execution pending appeal garnished ₱2.7 million from Mangondato’s SSS funds.
- CA CV 68061 and Present Appeal
- On 24 June 2005, the CA (CV 68061) denied NPC’s appeal, affirmed joint liability, and allowed NPC a credit of ₱2.7 million.
- NPC filed a petition for review on certiorari in the Supreme Court, challenging its remaining liability to Ibrahims and Maruhoms despite prior payment to Mangondato.
Issues:
- Whether NPC’s payment of rentals and indemnity to Mangondato under a final, executory judgment and writ of garnishment constituted bad faith—thus failing to extinguish its obligation toward the Ibrahims and Maruhoms.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)