Case Summary (G.R. No. 226138)
Background of RROW Compensation Claim
The government expropriated approximately 186,856 sqm of private land for the Cotabato-Kiamba-General Santos-Koronadal National Highway. The Olarte heirs secured RTC orders in 2007 instructing DPWH to pay just compensation in installments based on a Masterlist valuation dated June 30, 2007.
Dispute Over Ownership and Injunction Proceedings
Espina and Makar filed Civil Case No. 7788 in 2008, alleging they held valid titles and seeking a preliminary injunction to prevent DPWH payments to the Olarte heirs. The RTC granted TRO and WPI, later finding Espina and Makar as rightful owners via prior CA rulings, and directed DPWH to pay them PHP 218,839,455.00.
Appeals and Finality of Title Determinations
The Republic petitioned the CA (CA-G.R. SP No. 03310-MIN) and this Court (G.R. No. 202416), but both tribunals affirmed Espina and Makar’s titles as final. Subsequent RTC writs of execution were issued (June 2, 2010) and reimplementation orders followed after Espina and Makar’s ex parte motion.
CA Proceedings on Execution Orders
In CA-G.R. SP No. 06472-MIN, the Republic challenged RTC orders enforcing execution against DPWH funds. The CA affirmed in toto the RTC orders of December 16, 2013; February 24, 2014; and July 21, 2014, invoking res judicata based on G.R. No. 202416.
Issues Presented
- Whether the late-filed Motion for Partial Reconsideration may be entertained under exceptions to the immutability of final judgments.
- Whether COA approval is still required for disbursement of just compensation, given COA Resolutions Nos. 2021-008 and 2021-040.
- Whether legal interest should accrue on the just compensation award at 12% per annum from taking until June 30, 2013, and 6% per annum thereafter until full payment.
Supreme Court’s Disposition on Motion Timeliness
The Court invoked the exception for circumstances arising after finality that render execution unjust or inequitable. In the interest of substantial justice and fair play, it exercised discretion to entertain the Motion for Partial Reconsideration despite its late filing, given the significant impact of COA Resolution No. 2021-008 on the earlier directive.
COA Approval Requirement for Just Compensation
Article IX-D, Sec. 2(1) and PD 1445 grant COA broad audit powers. However, COA Resolutions Nos. 2021-008 and 2021-040 explicitly exclude “payment of just compensation based on a final judgment in expropriation proceedings” from COA Proper’s original jurisdiction, relegating such disbursements to post-audit. The Court held that requiring COA pre-approval would frustrate prompt payment and conflict with the constitutional mandate of just compensation under Art. III, Sec. 9. Consequently, it deleted the portion of the earlier judgment compelling respondents to file a money claim before COA.
Just Compensation a
Case Syllabus (G.R. No. 226138)
Facts
- The subject property comprises Lots A, G, and F, Plan SC-6834 (approx. 186,856 sqm) along the Cotabato–Kiamba–General Santos–Koronadal National Highway in General Santos City, taken by the State for public use.
- Vincente L. Olarte, as attorney-in-fact of the Olarte Hermanos y Cia Estate, claimed Road Right of Way (RROW) compensation; the RTC of Cotabato City ordered DPWH to pay PHP 44,891,140.65 in partial installments beginning 2007.
- Espina & Madarang, Co. and Makar Agricultural Corp. (respondents) filed Civil Case No. 7788 alleging that Olarte’s Original Certificate of Title (OCT) had been foreclosed, sold to El Hogar Filipino, and thereafter conveyed to them (Espina sisters and Makar), thus asserting ownership over the subject property.
- Respondents subdivided a portion of the property into 600 lots; 300 sold, 67 registered in vendees’ names.
Trial Court Proceedings
- May 2008: RTC Branch 36 in General Santos City granted a 72-hour TRO and subsequently issued a Writ of Preliminary Injunction in Civil Case No. 7788.
- DPWH manifested that it would halt payments pending resolution of the ownership dispute.
- October 5, 2009: RTC declared the injunction case moot and academic, upheld respondents’ ownership, and directed DPWH to pay PHP 218,839,455.00 as RROW compensation.
- Supplemental Order detailed the amount and instructed the Clerk of Court/Sheriff to assist in garnishment.
- Republic sought relief via petition for TRO/WPI before the Court of Appeals (CA SP 03310-MIN) and before the Supreme Court (G.R. No. 202416); both denied relief, finalizing respondents’ entitlement and DPWH’s liability.
- Respondents moved ex parte for prompt implementation of the June 2, 2010 Writ of Execution; RTC ordered levy, garnishment, and seizure of DPWH assets in lat