Case Digest (G.R. No. 172410)
Facts:
On December 29, 2000, the Republic of the Philippines, represented by the Toll Regulatory Board (TRB), filed a consolidated complaint for expropriation against landowners affected by the North Luzon Expressway expansion, including Holy Trinity Realty Development Corporation (HTRDC), docketed as Civil Case No. 869-M-2000 before the Regional Trial Court (RTC) of Malolos, Bulacan, Branch 85. On March 18, 2002, TRB deposited ₱28,406,700.00—equivalent to 100% of the zonal value of the subject properties—into an expropriation account with Land Bank of the Philippines (LBP) South Harbor and secured a writ of possession. HTRDC moved for reconsideration, while TRB sought Philippine National Police assistance to implement the writ. On March 3, 2003, HTRDC filed a motion to withdraw ₱22,968,000.00 of the deposit plus accrued interest, demonstrating absolute ownership and payment of taxes. The RTC granted release of the principal on April 21, 2003, and later held that interest earned on thaCase Digest (G.R. No. 172410)
Facts:
- Parties and Expropriation Proceedings
- Republic of the Philippines, through the Toll Regulatory Board (TRB), filed on December 29, 2000 a Consolidated Complaint for Expropriation (Civil Case No. 869-M-2000, RTC Malolos, Bulacan) for lands affected by the North Luzon Expressway project.
- Holy Trinity Realty Development Corp. (HTRDC) was one of the affected landowners.
- Deposits, Writ of Possession, and Interest Dispute
- On March 18, 2002, TRB deposited ₱28,406,700.00 (100% zonal value) with Land Bank of the Philippines (LBP) and secured a Writ of Possession on March 19, 2002.
- HTRDC moved to withdraw ₱22,968,000.00 of this deposit on March 3, 2003; RTC ordered withdrawal on April 21, 2003 but reserved the interest issue.
- After hearings, RTC on March 11, 2004 held that interest accrued on the ₱22,968,000.00 deposit “accrues to HTRDC by virtue of accession” and directed LBP to compute and release such interest to HTRDC.
- On February 7 and May 16 2005, RTC modified its position, deferring the interest issue to the determination of just compensation. HTRDC’s motion for reconsideration was denied.
- On April 21, 2006, the Court of Appeals (CA) in CA-G.R. SP No. 90981 reinstated the March 11, 2004 order, holding HTRDC entitled to the interest.
- TRB petitioned to the Supreme Court under Rule 45, contending landowners are entitled only to the zonal value, not accrued interest.
Issues:
- Primary Issue
- Whether the interest earned on the expropriation deposit belongs to HTRDC or remains with the government, pending final determination of just compensation.
- Subsidiary Issue
- Whether the interest claim should be deferred to the second stage of expropriation (just compensation determination) or resolved upon withdrawal of deposit.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)