Case Summary (G.R. No. 8429-27)
Background of the Case
The City of Manila filed a complaint on October 12, 1911, seeking to condemn certain lots, including those owned by the defendants, for street widening. The defendants admitted the City's right to condemn the property but contested the compensation amount, initially asserting damages of PHP 196,000. A commission was appointed to assess the properties and ultimately awarded the defendants PHP 119,173.40, which included both land and improvement costs.
Judicial Proceedings
On September 3, 1912, instead of confirming the commission's report as both parties had requested, the trial court disregarded their agreement and independently reduced the compensation to PHP 105,144.50. The defendants subsequently moved for a new trial, arguing that the trial court's actions were unjust and exceeded its authority, but this was denied, prompting an appeal.
Appellants' Argument
The appellants contended that the trial court was duty-bound to confirm the commission's report following the agreement made by both legal representatives in open court. They asserted that since both parties accepted the findings and requested confirmation, the court had no legal ground to alter the established agreement or findings.
Appellee's Counterargument
The City of Manila, through its representatives, rebutted the appellants’ claims, asserting that no binding agreement existed for the court to approve the commissioners' report. They suggested that the alleged agreement was a fabrication, with the basis of this argument rooted in a motion presented in court, which termed their submission of the report as devoid of any objection or formal consent to confirmation.
Court's Analysis
The court, upon reviewing the circumstances, noted the existence of a joint request for confirmation of the commission's report by both parties and found that while an explicit stipulation for judgment was not recorded until September 18, 1912, the earlier actions of both counsels amounted to sufficient agreement. This understanding warranted the court's obligation to recognize and uphold the verification of the commission's findings.
Conclusion on Judicial Authority
The court determined that the trial court exceeded its jurisdiction by disregarding the parties’ agreement to confirm the report without an adequate basis for doing so. Under Section 246 of the Code of C
...continue readingCase Syllabus (G.R. No. 8429-27)
Case Background
- On October 12, 1911, the City of Manila initiated a condemnation proceeding against certain lots of land, including properties owned by the defendants, for the purpose of widening a public street parallel to the Escolta in the Binondo district.
- The defendants acknowledged the city's right to condemn the properties but contested the amount of compensation, claiming damages of P196,000.
- A commission was appointed to assess the properties, which ultimately awarded the defendants a total of P119,173.40—P84,173.40 for the condemned land and P35,000 for improvements.
Court Proceedings
- Following the commission's report, the city attorney filed a motion to confirm the report and judgment in alignment with its findings.
- Both parties, in open court, verbally requested the court to confirm the commission's report.
- On September 3, 1912, the trial court disregarded the parties' agreement and the commission's findings, reducing the award to P105,144.50 without notice to the parties or additional evidence.
Appeal by the Defendants
- The defendants appealed, arguing that the trial court had a duty to approve the commission's report, as both parties had ag