Title
Republic vs. Legaspi, Sr.
Case
G.R. No. 177611
Decision Date
Apr 18, 2012
The Supreme Court upheld UP's expropriation rights, ruling that the RTC's denial of certain lots constituted grave abuse of discretion and violated due process.
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Case Digest (G.R. No. 177611)

Facts:

  • The Republic of the Philippines, represented by the University of the Philippines in the Visayas (UPV), is the petitioner.
  • Respondents include Rodolfo L. Legaspi, Sr., Querobin L. Legaspi, Ofelia Legaspi-Muela, Purisima Legaspi Vda. de Mondejar, Vicente Legaspi, Rodolfo Legaspi II, and spouses Rosalina Libo-on and Dominador Libo-on.
  • In December 1978, Rosalina Libo-on intended to sell a 40,133-square meter property in Miag-ao, Iloilo, to UPV.
  • A Deed of Definite Sale was executed, and UPV took possession for educational development.
  • On January 4, 1980, Rosalina rescinded the sale, claiming prior ownership transfer to the Legaspi respondents.
  • In August 1991, UPV filed for expropriation, asserting the property was vital for campus expansion.
  • The Regional Trial Court (RTC) initially allowed UPV to expropriate three lots but later denied the expropriation of seven lots on November 17, 2003, and May 31, 2004, citing their use for business and residential purposes.
  • UPV contested the RTC's decisions, leading to a petition for certiorari with the Court of Appeals (CA), which was denied on April 26, 2007.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court found merit in UPV's petition, reversing the CA's decision.
  • The Court nullified the RTC's orders dated November 17, 2003, and May 31, 2004.
  • The RTC was d...(Unlock)

Ratio:

  • The Supreme Court affirmed that the power of eminent domain is an inherent state right for condemning private property for public use, with just compensation.
  • Expropriation proceedings consist of two stages: determining the authority to expropriate and fixing just compensation.
  • The RTC's orders were deemed a grave abuse of discretion for lacking factual and legal justification for excluding cert...continue reading

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