Facts:

The case involves a petition for review on certiorari filed by Honorable Alvin P. Vergara, in his capacity as the City Mayor of Cabanatuan City, and the Sangguniang Panlungsod of Cabanatuan City (petitioners) against Lourdes Melencio S. Grecia, represented by Renato Grecia and Sandra Melencio, in representation of Ma. Paz Salgado Vda. de Melencio, Conchita Melencio, Cristina Melencio, and Leonardo Melencio (respondents). The events leading to this case began in 1989 when the Sanggunian took a parcel of land, covered by Transfer Certificate of Title No. T-101793, measuring approximately 7,420 square meters located in Barangay Barrera, Cabanatuan City, for road-right-of-way and road widening projects. Despite the completion of these projects, the Sanggunian failed to provide just compensation to the respondents. In response to Lourdes' request, the Sanggunian formed an appraisal committee to determine the appropriate compensation, which recommended a payment of P2,295.00 pe...

Facts:

1. Subject Property: The case involves a parcel of land covered by Transfer Certificate of Title No. T-101793, with an area of 7,420 square meters, located in Barangay Barrera, Cabanatuan City, and registered under the name of the respondents (Lourdes Melencio S. Grecia and others).

2. Taking of the Land: In 1989, the Sangguniang Panlungsod of Cabanatuan City (Sanggunian) took the subject land for road-right-of-way and road widening projects without paying just compensation to the respondents.

3. Appraisal Committee: Upon the respondents' request, the Sanggunian created an appraisal committee, which recommended a just compensation of P2,295.00 per square meter, totaling P17,028,900.00.

4. Memorandum of Agreement (MOA): On December 4, 2001, Mayor Julius Cesar Vergara executed an MOA with the respondents, agreeing to pay the compensation in 12 years. However, no payment was made despite the land being used by the public.

5. Denial of MOA Ratification: In 2002, the Sanggunian passed Resolution No. 129-2002, denying the ratification of the MOA due to fiscal constraints, rendering the MOA unenforceable.

6. Legal Action: On December 29, 2005, the respondents filed a petition for mandamus before the Regional Trial Court (RTC) of Cabanatuan City to compel the petitioners to pay just compensation.

7. RTC Decision: The RTC ruled in favor of the respondents, ordering the petitioners to pay P17,028,900.00 as just compensation, plus legal interest, attorney’s fees, and actual expenses.

8. Partial Execution: The RTC granted partial execution, ordering the petitioners to pay P10,000,000.00. The petitioners appealed, and the Court of Appeals (CA) reduced the amount to P2,554,335.00, representing 15% of the property’s value.

9. Petitioners’ Argument: The petitioners argued that the land is a subdivision road, beyond the commerce of man under Section 50 of Presidential Decree (P.D.) No. 1529, making the MOA void.

10. CA Decision: The CA affirmed the RTC’s decision but modified the amount to be paid. The petitioners filed a motion for reconsideration, which was denied, leading to this petition.

Issue:

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Ruling:

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Ratio:

1. Just Compensation: The right to just compensation is enshrined in the Constitution. The government cannot take private property for public use without paying fair compensation. The petitioners’ failure to pay for the land taken for road widening projects violates this constitutional guarantee.

2. Validity of the MOA: The MOA is valid and enforceable. The land is not beyond the commerce of man, as it was taken for public use, not as part of a subdivision. The petitioners’ reliance on Section 50 of P.D. No. 1529 is misplaced, as the provision applies to subdivision roads, not public thoroughfares.

3. Interest on Unpaid Compensation: Interest is imposed to compensate the respondents for the delay in payment. The delay in paying just compensation is a violation of the respondents’ rights, and the interest serves as a penalty for the petitioners’ failure to promptly pay.

4. Exemplary Damages and Attorney’s Fees: The award of exemplary damages and attorney’s fees is justified due to the petitioners’ oppressive actions and undue delay in paying just compensation. The Court aims to deter similar conduct by the government in the future.

5. Finality of Judgment: The Court emphasized that the issues raised by the petitioners had already been resolved in previous rulings. The petitioners’ arguments were without merit, and the Court upheld the CA’s decision with modifications to ensure that the respondents receive full and fair compensation.

Conclusion:

The Supreme Court denied the petition and affirmed the CA’s decision with modifications. The petitioners were ordered to pay the respondents P17,028,900.00 as just compensation, P200,000.00 as exemplary damages, and attorney’s fees equivalent to 1% of the total amount due. Legal interest was also imposed at 12% per annum from December 29, 2005, until June 30, 2013, and 6% per annum thereafter until full payment.