Case Digest (G.R. No. 226138)
Facts:
Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH) v. Espina & Madarang, Co. and Makar Agricultural Corp., G.R. No. 226138, February 27, 2024, Supreme Court En Banc, Lopez, J., writing for the Court. The petition originated from competing claims to Road Right of Way (RROW) compensation for lots traversed by the Cotabato–Kiamba–General Santos–Koronadal National Highway in General Santos City.The antecedent factual chain began with an undated claim by the heirs of Olarte (through an attorney-in-fact) for RROW compensation; Branch 14, RTC Cotabato issued orders directing DPWH to pay the Olartes, and DPWH made installment payments. Espina and Makar then sued (Civil Case No. 7788) the Olarte heirs, DPWH, and the Register of Deeds, alleging title transfers from the Olartes to El Hogar and then to Espina and Makar; the RTC granted a TRO and later a writ of preliminary injunction. DPWH informed the court it had already paid the Olartes and would cease payments pending resolution of ownership.
Following appellate rulings (including CA decisions—CA‑G.R. SP No. 02303‑MIN and CA‑G.R. SP No. 03310‑MIN) that sustained Espina and Makar’s ownership, the RTC, in October–November 2009 orders, upheld their ownership, fixed the amount due (PHP 218,839,455.00 per a Masterlist valuation as of June 30, 2007), and directed DPWH to pay; notices of garnishment, a writ of execution (issued June 2, 2010), and further RTC orders followed directing enforcement. The Republic sought relief from the CA (CA‑G.R. SP No. 03310‑MIN), which denied the petition; the Republic then sought review in this Court (G.R. No. 202416), but the Court dismissed the petition for being fact-bound.
After finality, Espina and Makar moved in the RTC to reimplement the June 2, 2010 writ of execution; the RTC ordered enforcement, including garnishment of DPWH assets. The Republic filed another petition with the CA (CA‑G.R. SP No. 06472‑MIN), which affirmed the RTC orders in toto. The Republic elevated the matter to this Court by petition for review. In its March 23, 2022 Decision (Third Division), this Court affirmed the CA but instructed Espina and Makar to first file a money claim with the Commission on Audit (COA) for satisfaction and enforcement of the money judgment. Espina and Makar filed a Motion for Partial Reconsiderati...(Subscriber-Only)
Issues:
- May this Court entertain respondents' Motion for Partial Reconsideration notwithstanding its late filing?
- Does COA Resolution No. 2021‑008 (as amended by COA Resolution No. 2021‑040) eliminate the requirement of prior COA approval or filing of a money claim before the COA for payment of just compensation based on a final court judgment?
- Should the just compensation awarded to respondents earn legal interest at 12% per annum from the date of taking until June 30, 2013, ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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