Title
Supreme Court
National Transmission Corp. vs. Bermuda Development Corp.
Case
G.R. No. 214782
Decision Date
Apr 3, 2019
BDC sued TransCo for unlawful detainer over a property TransCo occupied for public use. Courts ruled for BDC, but SC reversed, holding TransCo, a public utility with expropriation powers, cannot be evicted; BDC's remedy is just compensation, not ejectment.

Case Digest (G.R. No. 214782)
Expanded Legal Reasoning Model

Facts:

  • Unlawful Detainer and Initial Proceedings
    • On December 22, 2009, Bermuda Development Corporation (BDC) filed a case for unlawful detainer against National Transmission Corporation (TransCo) before the Municipal Trial Court (MTC) of Cabuyao, docketed as Civil Case No. 2498.
    • On January 23, 2009, TransCo filed its Answer, which contained both affirmative and compulsory counterclaims.
    • The MTC rendered its decision on August 24, 2009, ordering TransCo:
      • To vacate the subject lot (Lot 10-B, Psd. 043404-058243, 8,920 square meters located at Barangay Banlic, Cabuyao, Laguna) and remove all structures thereon.
      • To pay BDC a computed rental in the amount of ₱10,350,000.00 from December 13, 2008, until full vacation of the premises.
      • To pay additional costs including attorney’s fees and court appearance fees.
  • Appeals, Motions for Execution, and Garnishment
    • On September 17, 2009, TransCo appealed the MTC decision before the Regional Trial Court (RTC), Branch 24, of BiAan, Laguna.
    • BDC filed an Urgent Motion for Execution of the MTC decision, which was granted by RTC, Branch 24 on October 28, 2009, resulting in the issuance of a Writ of Execution.
    • Following this, on November 6, 2009, the RTC issued a Notice of Garnishment against TransCo’s account with Land Bank of the Philippines.
    • On November 10, 2009, TransCo filed an Omnibus Motion seeking:
      • Reconsideration of the RTC’s October 28, 2009 order.
      • Quashing of the writ of execution and the notice of garnishment.
  • Expropriation Proceedings
    • On January 21, 2010, TransCo filed a Complaint for Expropriation concerning the subject property (covered by TCT No. 258244) before RTC, eventually heard by Branch 25 as Civil Case B-7972.
    • On February 25, 2010, TransCo filed an urgent ex-parte motion before RTC Branch 25 for the issuance of a Writ of Possession. To support its motion, TransCo deposited ₱10,704,000.00 with Landbank, purportedly as the provisional value of the property.
    • RTC, Branch 25 then issued an Order granting the writ on March 29, 2010.
  • Dismissal of the Unlawful Detainer Appeal and Subsequent Developments
    • On July 29, 2010, RTC, Branch 24 dismissed TransCo’s appeal in the unlawful detainer case as “moot and academic,” noting that:
      • TransCo had initiated expropriation proceedings, effectively abandoning its appeal.
      • Possession of the property had already been delivered formally.
    • TransCo’s appeal dismissal led to ordering the enforcement of judgment on rental in arrears.
    • A motion for reconsideration was subsequently filed by TransCo but was denied on May 30, 2011, by RTC, Branch 24.
    • The Court of Appeals (CA) then affirmed the RTC orders in its Decision dated May 29, 2014 and denied further reconsideration on October 7, 2014.
    • National Transmission Corporation (TransCo) finally petitioned for review under Rule 45 of the Rules of Court.

Issues:

  • Whether the RTC erred in dismissing TransCo’s appeal on the ground that the case had become “moot and academic” due to the filing of expropriation proceedings for the same property.
  • Whether a case for recovery of possession (or ejectment) against a public service corporation—endowed with the power of eminent domain—can prosper, or if the proper remedy is solely the recovery of just compensation and consequential damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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