Case Summary (G.R. No. 198201)
Facts and Antecedent Proceedings
On December 22, 2009, BDC initiated an unlawful detainer action against TransCo in Cabuyao, Laguna, under Civil Case No. 2498. Following the trial, the Municipal Trial Court issued a decision on August 24, 2009, ordering TransCo to vacate the property, pay monetary damages, attorney’s fees, and costs of the suit. TransCo appealed this decision to the Regional Trial Court (RTC) of BiAan, Laguna, on September 17, 2009. Concurrently, BDC filed for an urgent motion for execution of the initial ruling, which the RTC granted, leading to the issuance of a writ of execution and a notice of garnishment against TransCo's bank account.
Expropriation Proceedings Initiated
In response to the ruling and BDC's actions, TransCo commenced expropriation proceedings concerning the same property on January 21, 2010. This case was assigned to RTC Branch 25 and resulted in the issuance of a writ of possession on March 29, 2010, after TransCo deposited the property value in court. Subsequently, on July 29, 2010, RTC Branch 24 dismissed TransCo's appeal in the unlawful detainer case as moot following the filing of the expropriation proceedings, leading to further unsuccessful motions for reconsideration by TransCo.
Ruling of the Court of Appeals
The Court of Appeals upheld the decisions of the RTC, concluding that it would create unnecessary delays to require TransCo to vacate the property, only to restore its possession due to the ongoing expropriation proceedings. It ruled that any rental amount due for the unlawful detainer case could be enforced as a separate judgment once finalized.
Issue Presented
The central question in this appeal was whether the RTC mistakenly dismissed TransCo's appeal on the grounds of being moot and academic, due to the initiation of the expropriation proceedings involving the property subject to the unlawful detainer case.
Court's Ruling
The Supreme Court found merit in TransCo’s petition. It cited prior jurisprudence indicating that cases involving the recovery of possession against a public utility corporation endowed with eminent domain powers cannot proceed as unlawful detainer actions. The Court emphasized that when a public utility such as TransCo occupies land without prior proper acquisition, the landowner's remedies are limited to claims for just compensation, rather than ejectment or injunction.
Public Policy Considerations
The Court reiterated the principle that public policy demands the uninterrupted operation of public utilities and thus prevents landowners from reclaiming p
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Background of the Case
- The case involves a Petition for Review under Rule 45 of the Rules of Court filed by the National Transmission Corporation (TransCo) against Bermuda Development Corporation (BDC).
- The Petition seeks to review and reverse the Decision dated May 29, 2014, and the Resolution dated October 7, 2014, of the Court of Appeals (CA) in CA-G.R. SP No. 120310.
- The CA Decision upheld the Orders dated July 29, 2010, and May 30, 2011, from the Regional Trial Court (RTC), Branch 24, of Biñan, Laguna, in Civil Case No. B-7880.
Factual Antecedents
- On December 22, 2009, BDC filed a case for Unlawful Detainer against TransCo in the Municipal Trial Court (MTC) of Cabuyao, which was docketed as Civil Case No. 2498.
- TransCo filed an Answer with Affirmative and Compulsory Counterclaim on January 23, 2009.
- The MTC rendered a Decision on August 24, 2009, ordering TransCo to vacate the property, pay reasonable monthly rental of P10,350,000.00, attorney's fees, and costs of the suit.
- TransCo appealed this decision to the RTC on September 17, 2009. Meanwhile, BDC filed an Urgent Motion for Execution of the MTC's Decision, which the RTC granted on October 28, 2009.
Subsequent Proceedings
- Following the issuance of a Writ of Execution, TransCo filed an Omnibus Motion for reconsideration on November 10, 2009.
- On January 21, 2010, TransCo initiated a Complaint for Expropriation of t