G.R. No. 241034 - Manila Hotel Corp. vs. Office of the Director, Bureau of Legal Affairs, Intellectual Property Office of the Philippines

Spouses Ciriaco and Arminda Ortega are the registered owners of Lot No. 310-B, situated in Hipodromo, Cebu City, with an area of 5,712 square meters, as evidenced by Transfer Certificate of Title No. 113311.
Cebu City, through its Sangguniang Panglungsod, is the opposing party in these consolidated petitions.

One-half of the parcel of land is occupied by squatters.
On September 24, 1990, the spouses Ortega filed an ejectment case against these squatters.
The ejectment case was decided in favor of the spouses Ortega at the Municipal Trial Court in Cities (MTCC) of Cebu City and eventually affirmed by the Supreme Court, rendering the decision final and executory with a writ of execution issued on February 1, 1994.

On May 23, 1994, Cebu City enacted Ordinance No. 1519, which authorized the expropriation of one-half (2,856 square meters) of the spouses Ortega’s land, appropriating P3,284,400.00 at a price of P1,150.00 per square meter.
The land’s appraised value was determined by the Cebu City Appraisal Committee in Resolution No. 19, Series of 1994, dated April 15, 1994.
Cebu City initiated a Complaint for Eminent Domain before the Regional Trial Court (RTC), Branch 23, Cebu City, under Civil Case No. CEB-16577.

On March 13, 1998, the RTC declared that Cebu City had the lawful right to expropriate the property for public use or purpose upon payment of just compensation.
Subsequently, on May 21, 1999, the RTC, based on the recommendations of appointed commissioners,:

Set the just compensation at P31,416,000.00, determining the value of the expropriated land at P11,000.00 per square meter.
The decision became final and executory after Cebu City’s failure to appeal.

On March 11, 2002, following a motion by the spouses Ortega, the RTC issued an order stating that the sum appropriated by Ordinance No. 1519 was now subject to execution or garnishment due to its approval by the City Council.
On July 2, 2003, the RTC, through a sheriff’s action, served a Notice of Garnishment on Philippine Postal Bank, garnishing Cebu City’s bank deposit.
Cebu City pursued multiple remedial motions:

Filed an Omnibus Motion to Stay Execution, Modification of Judgment, and Withdrawal of the Expropriation Case.
Subsequent motions for reconsideration on these issues were denied by the RTC.

Cebu City contested the garnishment order by filing an additional petition for certiorari (CA-G.R. SP NO. 00147) with the Court of Appeals.
Consolidation occurred:

The petitions in G.R. Nos. 181562-63 (filed by the spouses Ortega) and 181583-84 (filed by Cebu City) were consolidated before the Court of Appeals for review.

Cebu City further contended that the bank account garnished was never a valid account under Philippine Postal Bank, claiming that government funds should not be seized to satisfy judgments due to public policy considerations.

Whether the denial of Cebu City’s motion to modify the judgment and to withdraw from the expropriation proceedings was proper, given that the expropriation order had already become final and executory.

Whether the deposit (purportedly appropriated under Ordinance No. 1519) in Cebu City’s bank account with Philippine Postal Bank could be subject to garnishment for the payment of just compensation, particularly when the account was claimed not to have been specifically appropriated for that purpose and was contested as non-existent.