G.R. No. 45713 - Municipality of San Pedro, Laguna vs. Castillo

Case Summary (G.R. No. 45713)

Procedural History and Initiation of the Expropriation Case

The Government of the Commonwealth of the Philippines initiated civil case No. 6875 in the Court of First Instance of Laguna, naming the Colegio de San Jose and Carlos Young as defendants. The complaint alleged that the Colegio de San Jose claimed ownership over the large tract known as Hacienda de San Pedro Tunasan, while Carlos Young claimed entitlement to possession. The government asserted that it desired to expropriate a large parcel included in the hacienda and occupied by about one thousand one hundred sixty (1,160) tenants, and it prayed that P171,808 be provisionally fixed as the value of the land. It further prayed for authorization of the deposit and immediate delivery of possession to the government, without prejudice to the appointment of commissioners on appraisal to determine the correct value of the property.

Before the defendants filed their responsive pleadings, the Municipality of San Pedro intervened by filing a complaint in intervention against all parties, with leave of court. The intervenor alleged, in substance, that the hacienda and the expropriated portion belonged to the Commonwealth Government, or, as it put it, to the Philippine State by right of escheat; it claimed that it was the beneficiary of the hacienda and the parcel in question; it asserted that the value was merely P60,000; and it prayed for the appointment of Jose H. Guevara as commissioner representing it. It also sought delivery and payment, instead of to the defendants, of any sum fixed as value or indemnity.

Defendants’ Responses and the Issue of Provisional Value

The Colegio de San Jose and Carlos Young filed answers and amended answers to the government’s complaint and acknowledged the government’s right to expropriate the parcel described. They, however, disputed the value. They alleged that the value was P1,000,000 and that damages would not be less than P500,000. Carlos Young also requested final adjudication of P750,000 as damages incurred due to the expropriation, and he asked that the provisional value be raised to P1,500,000.

The government, the Colegio, and Carlos Young also filed answers to the petitioner’s complaint in intervention. The government indicated it had no objection to the court’s determination of the adverse rights of the intervenor and the defendants. The Colegio de San Jose denied that the petitioner had any right or interest in the hacienda or in the portion sought to be expropriated. It asserted that it was the registered owner and that its title and possession had been recognized from time immemorial. Carlos Young, likewise, impugned the intervenor’s claim by alleging that he was the lessee of the hacienda under a contract with the Colegio, which he characterized as the true and only owner.

Orders of the Trial Court: Denial of Release of Deposit and Appointment of Commissioners

By an order dated March 31, 1937, the Court of First Instance denied the motions of the Colegio de San Jose and Carlos Young for the delivery to them of the government’s deposited provisional value of P171,808, on the ground that the ownership was disputed between the petitioner and the Colegio.

On August 31, 1937, the trial court issued the order that prompted the petition for certiorari. The court appointed commissioners on appraisal: Mariano A. Garcia to represent the government, Fernando Quisumbinor to represent the Colegio de San Jose and Carlos Young, and Alfonso Farcon as the court’s own choice. The petitioner excepted to the order and moved for reconsideration, reasoning that the controversy between it and the Colegio had not been previously resolved and that Jose H. Guevara, which it proposed, had not been appointed commissioner. The trial court denied the motion for reconsideration.

The First Issue: Availability of Certiorari

The Court framed the first question as whether the petitioner was entitled to the remedy of certiorari. The Court reiterated the settled jurisdictional basis for certiorari in this jurisdiction: it lies only when the court issuing the order is without jurisdiction, has exceeded its jurisdiction, or has abused its sound discretion. It cited prior decisions establishing this doctrine, including Springer vs. Odlin, Gala vs. Cui and Rodriguez, and others.

Section 243 of the Code of Civil Procedure and Authority to Appoint Commissioners

The Court then examined Section 243 of the Code of Civil Procedure, governing appointment of commissioners in condemnation proceedings. The provision required the appointment of three judicious and disinterested landowners to hear the parties, view the premises, assess damages, and report to the court. It also contemplated the situation where the defendant concedes the right of condemnation: in that event, the court could immediately appoint commissioners to assess the property and determine damages.

Applying this rule, the Court held that the trial judge was authorized to proceed. The Court observed that the Colegio de San Jose and Carlos Young, in their answers, expressly admitted the government’s right to expropriate the portion of land described. Given this express admission, the Court concluded that the respondent judge properly acted within the authority conferred by Section 243 in appointing commissioners on appraisal.

The Intervenor’s Adverse Claims and Their Effect on the Appointment

The Court addressed the petitioner’s intervention theory. While the petitioner claimed adverse rights, the Court considered the nature of those rights based on the petitioner’s pleadings. It held that the petitioner’s asserted rights were limited to an alleged beneficiary interest, inferred from the complaint in intervention and the petition. It stressed that from the beginning of the expropriation proceedings, the petitioner did not contest the Commonwealth Government’s relation to the hacienda. It noted that the petitioner admitted that ownership or title to the Hacienda de San Pedro Tunasan resided in the Commonwealth of the Philippines. Conversely, the Court noted that the expropriation complaint also recognized the Colegio de San Jose as owner of the hacienda and of the portion sought to be expropriated.

On these premises, the Court declared that the petitioner could neither obstruct the expropriation proceedings nor prevent the trial court from naming commissioners pursuant to Section 243, because the rights invoked by the intervenor did not remove the court’s statutory authority to appoint commissioners where the defendants conceded the expropriation right.

Selection of Commissioners: Discretion of the Trial Court and Non-Delegation to Parties

The Court then addressed the petitioner’s additional ground: that the respondent judge failed to appoint the person proposed by the petitioner. It held that Section 243 left the selection of commissioners entirely to the sound discretion of the trial court. The only requirements were that the persons appointed be competent and disinterested landowners. The Court emphasized that the statute did not confer on the parties any right to select commissioners.

Timing of the Determination of Adverse Rights

The Court finally considered the petitioner’s argument that the respondent judge should not have appointed commissioners until after deciding the controversy between the petitioner and the Colegio de San Jose. The Court rejected this contention. It relied on two key circumstances appearing from the pleadings and the petitioner’s position: first, the petitioner did not question and did not dispute the government’s right to expropriate the large portion of the hacienda; second, the petitioner did not invoke any ownership right over the hacienda or any portion thereof. Accordingly, the Court held that, under Section 243, the respondent judge was not required to decide the adve

Case Syllabus (G.R. No. 45713)

Parties and Procedural Posture

The Municipality of San Pedro, Laguna filed a petition for certiorari to set aside an order of August 31, 1937 issued by Modesto Castillo, then Judge of First Instance of Laguna, in civil case No. 6875.
The respondent judge issued the challenged order appointing commissioners on appraisal in an expropriation case.
The Government of the Commonwealth of the Philippines instituted civil case No. 6875 against the Colegio de San Jose and Carlos Young as defendants.
The petitioner municipality intervened in the expropriation case through a complaint in intervention against the parties.
The petitioner sought not only the nullification of the August 31, 1937 appointment order but also an order compelling the respondent judge to determine beforehand the adverse rights it invoked as intervenor and to appoint commissioners representing each party.
The respondent judge denied the petitioner’s motion for reconsideration after the August 31, 1937 order was issued.
The Court resolved whether certiorari lay, and it denied the petition.

Key Factual Allegations

The complaint in civil case No. 6875 alleged that the Colegio de San Jose claimed ownership of the entire tract known as Hacienda de San Pedro Tunasan and that Carlos Young claimed entitlement to possession.
The complaint further alleged that the government desired to expropriate a large parcel included in the hacienda and occupied by about 1,160 tenants.
The complaint prayed that P171,808 be provisionally fixed as the value of the land sought to be expropriated, that deposit of the amount be authorized, and that delivery of possession to the government be ordered forthwith, without prejudice to the appointment of commissioners on appraisal.
Before the defendants filed their answers, the petitioner municipality, with court authority, filed a complaint in intervention asserting that the Hacienda de San Pedro Tunasan, including the portion sought to be expropriated, belonged to the government or to the Philippine State by right of escheat.
The petitioner alleged it was the beneficiary of the entire hacienda and the expropriated portion and that the value of the parcel was merely P60,000.
As remedies, the petitioner asked for the appointment of Jose H. Guevara as commissioner to represent it and asked that delivery and payment of any appraisal amount be made to it instead of the defendants.
The defendants, Colegio de San Jose and Carlos Young, denied the municipality’s claimed interest and acknowledged the government’s right to expropriate but placed the land value substantially higher.
The defendants alleged that the value of the expropriated portion was P1,000,000 and that damages would not be less than P500,000.
Carlos Young asked for a final adjudication of P750,000 in damages allegedly incurred due to the expropriation and for a raise of the provisional value to P1,500,000.
The government stated it had no objection to the court’s determining the adverse rights of the intervenor and defendants.
Colegio de San Jose alleged it was the registered owner and that title and possession had been recognized from time immemorial.
Carlos Young asserted that he was the lessee of the hacienda under a contract with Colegio de San Jose, which he claimed as the true owner.
By an order of March 31, 1937, the trial court denied the defendants’ petition to deliver the provisional deposit of P171,808 because the municipality and Colegio de San Jose disputed ownership.
On August 31, 1937, the trial court appointed commissioners: Mariano A. Garcia for the government, Fernando Quisumbinor for Colegio de San Jose and Carlos Young, and Alfonso Farcon as the court’s choice.
The petitioner excepted and moved for reconsideration because it asserted that the person it proposed, Jose H. Guevara, was not appointed.

Statutory Framework

The Court applied the doctrine on certiorari, reiterating that it lies only when the court that issued the order acted without jurisdiction, exceeded its jurisdiction, or abused its sound discretion.
The Court relied on Section 243 of the Code of Civil Procedure, which governs the appointment of commissioners in condemnation proceedings.
The Court quoted Section 243, which provides that if the defendant concedes the right of condemnation or if, upon trial, the court finds the right exists, the court shall appoint three judicious and disinterested landowners to hear the parties, view the premises, assess damages, and report to the court.
The Court