G.R. No. L-35910 - Bersabal vs. Salvador

This case involves an expropriation proceeding filed by the Department of Public Works and Highways (DPWH) representing the Republic of the Philippines against Casimiro Tamparong, Jr., the owner of the subject land.
The Complaint, filed on February 2, 1999, concerned a 7,555-square meter land in Barangay Kauswagan, Cagayan de Oro City, intended for the Cagayan de Oro Third Bridge and Approaches Project.
On November 27, 2000, the Regional Trial Court (RTC), Branch 24, issued an Order of Expropriation, affirming the government's lawful right to take the property for public use.
On November 29, 2000, the same RTC branch issued an order placing the Republic in immediate possession of the property.

Years of hearings followed to determine the just compensation due to Tamparong.
On January 21, 2010, RTC Branch 20 resolved the issue by ordering the Republic to pay Php 3,500.00 per square meter for the 7,555 square meter lot, deducting a provisional deposit of Php 9,443,750.00 already paid.
The payment was to include legal interest from the taking of possession until the actual payment, thus ensuring compensation for the delay.
The resolution became final and executory because no motion for reconsideration or appeal was filed.

Controversy arose over the computation of the remaining balance at execution.
A Writ of Execution issued on March 7, 2013, indicated a remaining balance of Php 27,651,129.77 based on Tamparong's computation.
Upon Republic's motion for clarification, an Amended Writ of Execution was issued deleting exact monetary figures but reiterating the court order on just compensation and interest.
DPWH sent a letter on January 13, 2014, proposing its computation of the balance payable: interest at 6% per annum from the taking and 12% per annum from finality of judgment until December 11, 2013.
Tamparong's counsel responded on February 18, 2014, requesting immediate payment but insisted on interest at 12% per annum from the time of taking to conform to jurisprudence.
Tamparong filed a Motion for Recomputation on March 5, 2014, asking the court to direct DPWH to recompute with 12% interest.

On June 25, 2014, RTC Branch 20 ordered legal interest fixed at 12% per annum from the date of the January 21, 2010 resolution until payment, less amount already paid.
The Republic filed a Motion for Reconsideration arguing the 12% interest was only for delays in payment, but claimed no delay due to substantial provisional payments made.
The Motion was denied on August 26, 2014.
The Republic petitioned the Court of Appeals (CA) for certiorari, contesting the imposition of 12% interest.

The CA affirmed the RTC's order imposing 12% interest, finding no grave abuse of discretion.
The Republic brought the petition to the Supreme Court, maintaining that no delay existed as provisional payments were made and imputing delay to Tamparong's refusal to accept DPWH's computation.
Tamparong argued bad faith by DPWH due to incorrect interest computation and reiterated the 12% interest rate based on jurisprudence.
Tamparong also cited his advanced age and poor health as reasons for requesting immediate payment.

Mediation efforts were ordered by the CA in 2016 after Tamparong accepted DPWH’s offer of Php 17,253,596.76 without reservation, considering his health condition.
No compromise agreement was reached, and Tamparong died on December 3, 2018, without receiving full payment.

Whether the imposition of 12% legal interest per annum on the just compensation from the time of the property taking until full payment was justified despite provisional payments.
Whether the Republic's provisional payment of just compensation negated the accrual of legal interest.
Whether the DPWH's computation of interest at 6% per annum conformed with prevailing jurisprudence and the court's orders.