Case Summary (G.R. No. 266880)
Factual Background and Legal Proceedings
The controversy began after TRANSCO allegedly encroached on the properties in early 2017, removing existing structures and trees, and declaring ownership over the lands for the improvement of the electricity transmission system. In response, the property owners filed a complaint for inverse condemnation under the Rules of Court, asserting their rights as registered owners to just compensation. TRANSCO countered by claiming that the complaint lacked merit. The Regional Trial Court (RTC) eventually ruled in favor of the property owners, ordering TRANSCO to deposit an amount representing 100% of the current zonal valuation of the affected properties.
Procedural History and Motions Filed
TRANSCO subsequently filed motions to archive the case and to implead the National Grid Corporation of the Philippines (NGCP) as an indispensable party, arguing that the case could not be fully resolved without NGCP's involvement. The RTC denied both motions, stating that NGCP's presence was not critical for a judgment on the merits. Following a series of procedural missteps, including late filings and fee discrepancies attributed to the COVID-19 pandemic, TRANSCO’s attempts to appeal failed due to jurisdictional defects.
Court of Appeals' Decision
The Court of Appeals (CA) dismissed TRANSCO's Petition for Certiorari based on these procedural grounds, leading to the current appeal where TRANSCO argues that the CA erred in applying strict procedural standards and insists on the necessity of NGCP’s involvement in the case.
Judicial Discretion and Relaxation of Procedural Rules
In the Supreme Court's ruling, it was underscored that the right to file a special civil action of certiorari is discretionary rather than an absolute right. The Court recognized the need for judicial discretion when applications of procedural rules could hinder the pursuit of justice, particularly noting the challenges posed by the pandemic and the compelling merits of TRANSCO's case related to potential unjust compensation to the property owners.
Examination of Indispensable Parties
The Court examined TRANSCO's motion to implead NGCP, emphasizing the importance of determining whether NGCP was indeed an indispensable party. Following established legal standards, an indispensable party is one whose absence would inhibit the court from rendering a complete and effective judgment.
Conclusion on Indispensable Parties
After evaluating the facts, the Court determi
...continue readingCase Syllabus (G.R. No. 266880)
Background and Parties Involved
- The case involves a Petition for Review on Certiorari filed by the National Transmission Corporation (TRANSCO) challenging resolutions of the Court of Appeals dismissing its Petition for Certiorari.
- The respondents, including Clemente P. Untiveros and several spouses and heirs, filed a Complaint for inverse condemnation due to alleged illegal encroachment and property rights issues concerning transmission lines.
- TRANSCO is a government-owned corporation created under Republic Act No. 9136, responsible for power transmission system operations, whose functions were later delegated to the National Grid Corporation of the Philippines (NGCP) under a Concession Agreement.
Nature of the Controversy
- Encroachment by TRANSCO in early 2017 on seven parcels of land owned by the respondents in Barangay Bucal, Batangas City involving property removals and restrictions within 40 meters of the transmission line.
- Respondents filed inverse condemnation claims under Rule 67 and Republic Act No. 10752 to compel TRANSCO to exercise eminent domain power and pay just compensation.
- TRANSCO asserted ownership and necessity to improve electricity transmission system, denied the claims, and filed counterclaims.
Procedural History
- The Regional Trial Court (RTC) denied TRANSCO's motions to archive the case and to implead NGCP as an indispensable party.
- RTC ordered TRANSCO to deposit provisional just compensation based on BIR zonal valuation.
- The Court of Appeals dismissed TRANSCO's Petition for Certiorari on procedural grounds including late filing, incomplete payment of docket fees, lack of proof of service, and absence of certified true copies of RTC resolutions.
- The Supreme Court review was sought by TRANSCO.
Legal Issues Presented
- Whether the Court of Appeals erred in strictly applying procedural rules in dismissing TRANSCO's petition.
- Whether NGCP is an indispensable party in the inverse condemnati