G.R. No. 266880 - National Transmission Corporation vs. Clemente P. Untiveros, et al.

The petitioner is the National Transmission Corporation (TRANSCO), a government-owned and controlled corporation, initially tasked with the operation and maintenance of the nationwide power transmission system.
The respondents are Clemente P. Untiveros, spouses Jose V. and Teodora M. Pagcaliwagan, Lucila M. Plata, heirs of Juan and Geronima Torres, spouses Leonisa and Natalio Lopez, spouses Bernardo and Anita Pagcaliwagan, all represented by Freddie M. Arguelles (Untiveros et al.).
Untiveros et al. claimed ownership of seven parcels of land in Barangay Bucal, Batangas City, allegedly affected by the Batangas-Makban 230KV Transmission Line owned by TRANSCO.

TRANSCO’s transmission functions were turned over to the National Grid Corporation of the Philippines (NGCP) on January 15, 2009, under Republic Act No. 9511 and a Concession Agreement among PSALM, TRANSCO, and NGCP.
In early 2017, TRANSCO removed structures and trees from the subject properties, citing restrictions within a 40-meter range of the transmission lines and asserting ownership for system improvement.
Untiveros et al. filed a Complaint for inverse condemnation under Rule 67 and Republic Act No. 10752 against TRANSCO to compel the exercise of eminent domain and payment of just compensation.
TRANSCO filed an Answer with defenses and a Counterclaim, denying the claim’s merit.
Untiveros et al. filed a Motion requiring TRANSCO to comply with Republic Act No. 10752 by depositing provisional compensation based on the BIR’s zonal valuation.
The RTC granted this motion, ordering TRANSCO to deposit PHP 138,448,000.00 as 100% provisional compensation based on current zonal valuation, despite TRANSCO’s opposition.

TRANSCO moved to archive the case and to implead NGCP as an indispensable party, given NGCP’s operational control of the transmission assets since 2009.
The RTC denied both the Motion to Archive and the Motion for Leave to Implead Indispensable Party, stating that NGCP was not necessarily indispensable and archiving was inappropriate for this ground.
TRANSCO’s Motion for Reconsideration was also denied.

Untiveros et al. obtained a cease and desist order against TRANSCO to prevent entry and use of the subject properties pending final possession.
TRANSCO filed a Petition for Certiorari with the Court of Appeals (CA), assailing the RTC’s denial of motions.
The CA dismissed TRANSCO’s Petition on procedural grounds: late filing, incomplete docket fees, failure to serve parties, and non-attachment of certified copies.
TRANSCO moved for reconsideration, which was denied by the CA.
TRANSCO subsequently filed a Petition for Review on Certiorari before the Supreme Court, arguing for leniency in procedural lapses due to COVID-19 disruptions and emphasizing the importance of impleading NGCP to avoid unfair financial liability.

Whether the Court of Appeals erred in dismissing TRANSCO’s Petition for Certiorari strictly on procedural grounds without considering the substance of the controversy and the challenges posed by the pandemic.

Whether the Regional Trial Court erred in denying TRANSCO’s Motion for Leave to Implead NGCP as an indispensable party in the inverse condemnation case.

Whether the denial of the Motion to Archive the case pending NGCP’s impleader was proper.