G.R. No. 37271 - People vs. Caliso

In 2007, Vincente L. Olarte, attorney-in-fact for the Olarte Hermanos y Cia Estate, claimed Road Right of Way (RROW) compensation from DPWH for Lots A, G, and F along the National Highway in General Santos City. The Regional Trial Court (RTC), Branch 14, Cotabato City, ordered DPWH to pay the claim in installments beginning November 2007.
On May 7, 2008, Espina & Madarang, Co. and Makar Agricultural Corp. filed Civil Case No. 7788 in RTC Branch 36, General Santos City, challenging the heirs’ title and claiming ownership by virtue of subsequent transfers from El Hogar. The RTC issued a 72-hour TRO and then a Writ of Preliminary Injunction on June 24, 2008, enjoining DPWH payments to the Olarte heirs.

The Court of Appeals (CA) in CA-G.R. SP No. 02303-MIN (July 22, 2009) affirmed Espina and Makar’s ownership. The RTC then upheld their ownership in Orders of October 5 and November 13, 2009, directing DPWH to pay PHP 218,839,455.00 and issuing a writ of execution on June 2, 2010.
The Republic petitioned the CA (CA-G.R. SP No. 03310-MIN) and this Court (G.R. No. 202416), both denied. Espina and Makar secured reimplementation of the writ. In CA-G.R. SP No. 06472-MIN, the CA (January 25, 2016) affirmed the RTC Orders. This Court in G.R. No. 226138 (March 23, 2022) partly granted the Republic’s petition by affirming res judicata but enjoined Espina & Madarang and Makar to file a money claim with the Commission on Audit (COA). Espina and Makar filed a Motion for Partial Reconsideration, prompting the present resolution.

Whether this Court may entertain Espina & Madarang’s and Makar’s Motion for Partial Reconsideration despite its late filing.
Whether COA approval is still required for disbursement of just compensation in light of COA Resolution No. 2021-008 (as amended by COA Resolution No. 2021-040).
Whether the just compensation of PHP 218,839,455.00 should earn legal interest at 12% per annum from date of taking until June 30, 2013, and 6% per annum thereafter until full payment.