Case Digest (G.R. No. 95146)
Facts:
In Republic of the Philippines, represented by the General Manager of the Philippine Information Agency (PIA), vs. The Honorable Court of Appeals and the Heirs of Luis Santos, G.R. No. 146587 (July 2, 2002), the PIA instituted expropriation on September 19, 1969 in RTC Bulacan (Civ. Nos. 3839-M to 3842-M) over 544,980 sqm along MacArthur Highway, Malolos, Bulacan, depositing ₱517,558.80 as provisional just compensation. On February 26, 1979, the RTC condemned the land at ₱6.00 per sqm with 12% legal interest from the date of taking and awarded fees and costs. The heirs of Luis Santos, entitled to 76,589 sqm, remained unpaid. On May 9, 1984 they moved for payment; the RTC issued a writ of execution on June 7, 1984 and ordered partial release (₱72,683.55) on July 10, 1984. Despite Proclamation No. 22 by President Estrada transferring portions of the land to Bulacan State University and for carabao propagation, respondents were still unpaid. On September 16, 1999 PIA sought to depoCase Digest (G.R. No. 95146)
Facts:
- Expropriation proceedings initiated in 1969
- On September 19, 1969, the Philippine Information Agency (PIA) filed Civil Cases Nos. 3839-M to 3842-M in the Regional Trial Court (RTC) of Bulacan to expropriate 544,980 sqm along MacArthur Highway, Malolos, Bulacan, for radio‐transmitter facilities.
- PIA deposited ₱517,558.80 as provisional just compensation.
- 1979 RTC decision and subsequent non‐payment
- On February 26, 1979, the RTC rendered a final decision condemning the properties, fixing compensation at ₱6.00/sqm with 12% legal interest from September 19, 1969, and awarding costs.
- The 76,589 sqm formerly owned by Luis Santos (predecessor‐in‐interest of respondents) formed part of the expropriated tract but remained unpaid.
- Heirs’ motions and partial release of deposit in 1984
- On May 9, 1984, respondents manifested non‐payment and sought implementation; on June 7, 1984, the RTC issued a writ of execution.
- On July 10, 1984, the RTC ordered release of ₱72,683.55 (respondents’ share of the 1969 deposit) via the provincial treasurer.
- Presidential transfers and renewed motions
- By Proclamation No. 22 (1999), President Estrada transferred 20 ha to Bulacan State University and 5 ha for carabao propagation; the remainder stayed with PIA.
- On September 16, 1999, PIA moved to deposit ₱4,664,000 as compensation; respondents counter-moved to revalue at ₱5,000/sqm or to return the land.
- On March 1, 2000, the RTC vacated its 1979 decision as “unenforceable by prescription,” denied PIA’s motion, and ordered return of the property. The Court of Appeals denied PIA’s certiorari petition.
- Supreme Court proceedings
- PIA petitioned the Supreme Court, urging public‐interest consideration and urging decision on the merits.
- The Supreme Court granted the petition, set aside the CA and RTC orders, and reinstated the 1979 decision for immediate execution.
Issues:
- Prescription of execution
- Does Section 6, Rule 39, of the Rules of Court bar execution of the 1979 judgment by motion after five years?
- Did respondents’ 1984 motions or partial release of deposit interrupt the five-year prescriptive period?
- Availability of property recovery
- May respondents recover possession of the expropriated land instead of demanding just compensation?
- Was PIA’s transfer under Proclamation No. 22 valid despite non‐payment?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)