Case Digest (G.R. No. 194190) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines v. Spouses Francisco R. Llamas, the Department of Public Works and Highways (DPWH) filed an expropriation case on April 23, 1990 before the Regional Trial Court (RTC) of Parañaque City to widen Dr. A. Santos Avenue. Commissioners later recommended just compensation at ₱12,000.00 per square meter. On January 27, 1994, Francisco and Carmelita Llamas, asserting that 298 square meters of their lots (covered by TCT Nos. 217167 and 179165) were taken, moved to intervene as defendants-intervenors. The DPWH countered that only 41 square meters in TCT No. 179165 had been affected and did not dispute the ₱12,000.00 valuation. After years of motions and exchanges, the RTC by Order dated October 8, 2007 required DPWH to pay the Llamas Spouses ₱12,000.00 per square meter for the 41 square meters in TCT No. 217267 but denied compensation for the two subdivision road lots in TCT No. 179165 on the ground they “no longer owned” them. The RTC denied reconsideration Case Digest (G.R. No. 194190) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Expropriation Proceedings Before the Regional Trial Court (RTC)
- On April 23, 1990, the DPWH filed an expropriation suit (Civil Case No. 90-1069) to widen Dr. A. Santos Ave. (Sucat Road) in Parañaque City, affecting 26 defendants.
- On November 2, 1993, the court-appointed commissioners recommended just compensation of ₱12,000.00 per square meter.
- On January 27, 1994, spouses Francisco and Carmelita Llamas moved to intervene, claiming exclusion despite affected properties.
- In their March 21, 1994 Answer-in-Intervention, they alleged 298 m² taken across three parcels:
- 102 m² from Lot 4, Block 3 (TCT No. 217167)
- 84 m² from Lot 1 (TCT No. 179165)
- 112 m² from Lot 2 (TCT No. 179165)
- On August 2, 1994, the Llamases sought immediate payment of 40% zonal value; DPWH opposed on December 9, 1994, asserting only 41 m² were affected and contesting any improvements.
- On May 29, 1996, the RTC issued an order fixing compensation for other defendants but excluded the Llamases.
- The Llamases filed a May 14, 2002 Motion for Writ of Execution; DPWH filed comments. By joint motion in November 2002, both agreed to suspend proceedings pending submission of titles and tax documents.
- On October 8, 2007, the RTC directed DPWH to pay ₱12,000.00/m² for 41 m² under TCT No. 217167 and denied payment for the subdivision road lots (TCT No. 179165), deeming them community property.
- On May 19, 2008, the RTC denied the Llamases’ motion for reconsideration.
- Proceedings Before the Court of Appeals (CA)
- The Llamases secured a petition for certiorari; on October 14, 2010, the CA reversed the RTC orders.
- The CA ordered DPWH to pay ₱12,000.00/m² for a total of 237 m² (inclusive of all three lots) plus 12% interest per annum from the time of taking.
- Petition for Review in the Supreme Court
- On January 25, 2017, the Supreme Court resolved the Rule 45 petition by DPWH seeking reinstatement of the RTC orders.
- DPWH argued the subdivision road lots were not compensable, citing White Plains jurisprudence and Presidential Decree No. 957.
- The Llamases maintained that no donation occurred and their parcels retained private character subject only to an easement.
Issues:
- Whether just compensation must be paid for the subdivision road lots covered by TCT No. 179165.
- Whether subdivision road lots, once delineated, are automatically withdrawn from commerce and thus non-compensable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)