G.R. No. L-46845 - Santiago vs. Court of Appeals

The Export Processing Zone Authority (EPZA) initiated expropriation proceedings involving two parcels of land, namely Lot Nos. 190 and 293, covered by Transfer Certificates of Title (TCT) Nos. 22484 and 22485, respectively.
Private respondents, owners of the lots, were named as defendants since their properties were subject to expropriation.
The power of EPZA to initiate the expropriation was not in dispute; the controversy centered on the determination of just compensation.

To determine the amount of just compensation, the presiding judge (petitioner) of the Court of First Instance appointed three commissioners who rendered their findings based on market evaluations.
Before a judgment could be entered, the parties reached an amicable settlement regarding:

The compensation amount for the expropriated lands.
The sale of another parcel of land covered by TCT No. 22483 to EPZA, resulting in new titles being issued in EPZA’s name.

Despite the settlement reached during the pendency of the proceedings, the petitioner judge ordered the submission of the deeds of sale to assess their legality and conformity with law, morals, good customs, public order, and public policy.

The first deed of sale involved Lot No. 190 and the additional parcel (TCT No. 22483):

Sold for Three Hundred Forty-Nine Thousand and Six Pesos (P349,006.00).
The declared market value of Lot No. 190 was Four Hundred Sixty-Four Thousand, Seven Hundred Pesos (P464,700.00), while the Provincial Assessor appraised it at One Hundred Twenty-Three Thousand, Nine Hundred Eighty-One Pesos and Ninety-Six Centavos (P123,981.96).

Sold for One Million Three Hundred Ninety-Five Thousand, Nine Hundred Sixty-Eight Pesos (P1,395,968.00).
The declared market value was Twenty-Nine Thousand, Nine Hundred Thirteen Pesos and Sixty Centavos (P29,913.60), with an assessor’s valuation of Twenty-Seven Thousand, Four Hundred Twenty Pesos and Eighty Centavos (P27,420.80).

The petitioner judge found that both transactions were grossly above the market values and in violation of Presidential Decree No. 76, which mandates that just compensation be based on the lower of the owner’s declared market value or the assessor’s determination.

On October 29, 1975, the petitioner judge rejected the amicable settlement, declared it invalid, and ordered the case to proceed further based on his assessment of the deeds of sale.
The parties filed a motion for reconsideration, which the judge denied.
The matter was elevated to the Court of Appeals, which reversed the petitioner judge’s order by validating the amicable settlement, thereby setting aside his rejection of the agreement.

In response to the reversal by the Court of Appeals, the petitioner judge filed a petition for review seeking the reinstatement of his earlier order.
The core issue arose as to whether a judge, in his official capacity, may file such a petition when he was not an actual party in either the expropriation proceeding or in the certiorari proceeding before the Court of Appeals.
The petitioner was included as a nominal respondent in the higher court proceedings solely to satisfy procedural requirements, as established in prior cases like Mayol v. Blanco and reiterated in Alcasid v. Samson.

Whether the judge abused his discretion in nullifying the deeds of sale and proceeding with the expropriation despite an amicable settlement.
Whether the petitioner judge possessed the legal capacity or standing to file a petition for review concerning his own order, given that he was not a proper party in either the original expropriation proceeding or the subsequent certiorari proceeding.
Whether a judge, acting solely in his official capacity, may participate as an active litigant by seeking reversal of a decision rendered by a higher court.