G.R. No. 166964 - Tiongson vs. National Housing Authority

On April 3, 1987, the National Housing Authority (NHA) filed a complaint for eminent domain with the Regional Trial Court (RTC) of Manila, Branch 35, against petitioners who are the owners of several lots located in Tondo, Manila.
The lots in question have a total area of 66,783.40 square meters and an aggregate appraised value of P21,024,136.50.
Instead of filing an answer, petitioners resorted to motions to dismiss, coupled with a prayer for actual, moral, exemplary damages and attorney’s fees.

On March 11, 1988, NHA deposited an amount of P21,107,485.07 as provisional just compensation at the Philippine National Bank (PNB); this was evidenced by Certificate of Time Deposit No. 233991-B.
The deposited amount was maintained in PNB (Escolta Branch) Fiduciary Account No. 068-576012-6.
On March 11, 1991, the RTC rendered a decision dismissing NHA’s complaint for eminent domain, while also dismissing petitioners’ counterclaims.
The Court of Appeals affirmed this decision on February 26, 1993.

On petition before the Supreme Court, the case was declared terminated for NHA’s failure to file the petition on time.
The resolution declaring termination became final and executory on July 26, 1993.
Nearly seven years later, on September 7, 2000, NHA filed a motion for leave to withdraw the deposit, though without specifying a hearing date.
A second motion for leave to withdraw the deposit was subsequently filed on October 30, 2000, scheduling a hearing on November 10, 2000.

On November 8, 2000, the RTC issued an Order expunging the first motion from the records.
The RTC declared that the withdrawal amount would serve as:

Petitioners were informed that they might have sustained damages during the expropriation process, which they could either pursue or waive.
NHA’s motion for reconsideration on this matter was denied on December 8, 2000.

Petitioners argued that the Court of Appeals abused its discretion and acted either without or in excess of jurisdiction by:

Granting NHA’s motion to withdraw its deposit despite alleged lack of notice for a hearing, and
Allowing the withdrawal motion to be approved prior to a hearing that would determine the extent of damages allegedly sustained by petitioners as a result of the dismissal of the expropriation complaint.

Petitioners also contended that by dismissing their counterclaim, they were barred from presenting evidence to substantiate their damage claims.

For the entire seven-year period after the finality of the dismissal (July 26, 1993), petitioners did not file any motion, pleading, or claim to secure a hearing or evidence regarding their alleged damages.
The records indicate that petitioners took no procedural steps to pursue the recovery of damages during this period.

Whether the Court of Appeals committed grave abuse of discretion, amounting to lack or excess of jurisdiction, in granting NHA’s motion to withdraw its deposit:

Considering that the motion allegedly lacked proper notice for a hearing.
Whether the motion should have been dismissed as a mere scrap without procedural effect.

Whether the Court of Appeals improperly approved the withdrawal of NHA’s deposit prior to holding a hearing to determine:

The extent of damages sustained by petitioners resulting from the final and executory dismissal of the expropriation complaint.
The proper assessment and validation of petitioners’ claims for actual, moral, and exemplary damages, along with attorney’s fees.