Case Summary (G.R. No. L-38587)
Relevant Facts
The petition for expropriation was filed on July 10, 1963, with an order issued the following day by Judge Guillermo Dacumos, establishing a provisional value for the property at P1,050.48. After more than three years, a motion was submitted to withdraw part of this deposit, which was subsequently granted. However, it took the court more than five years, until December 9, 1971, to formally set the final just compensation for the property at P18,137.68, including interest, thereby recognizing the substantial delay in awarding compensation for the expropriated land.
Legal Basis for Compensation
Article III, Section 1, paragraph 2 of the 1935 Philippine Constitution, echoed in the current Constitution, mandates that “private property shall not be taken for public use without just compensation." This fundamental principle underscores the court's obligation to ensure the payment of just compensation is made to owners whose property has been expropriated, highlighting the intrinsic link between eminent domain and due process.
Judicial Findings
The court dismissed the petition for certiorari brought forth by the Province, concluding that the arguments made were not valid and lacked merit. The petitioners contended that there was no final judgment regarding the order issued by Judge Domondon for lack of adequate descriptions concerning the property. However, the court reasoned that the description provided in both the earlier complaint and the order met the legal requisites, sufficient to identify the property being expropriated and the intended public use.
Conclusion on Petition's Validity
The court characterized the claim that the order was a "patent nullity" as exaggerated, based primarily on a misinterpretation of the procedural law provided in Section 13 of Rule 67 of the Rules of Court. Despite acknowledging that the order could have had a more precise description, the court emphasized that the rights and obligations pertaining to just compensation must not be undermined by formal imperfections that do not affect the substance of the order. Ultimately, the court reaffirmed that
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Case Background
- The case involves the Province of Pangasinan as the petitioner against various respondents, including the presiding judge and private property owners Socorro Roy, Manuel R. Magno, Godofredo R. Magno, Rosalia M. Salcedo, Rebecca M. Reyes, Aurora M. Panaguiton, and Jose S. Ubaldo.
- The core issue is the delay in the payment of just compensation for a lot that was expropriated for school purposes, with the property having been in the Province's possession since 1963.
Timeline of Events
- July 10, 1963: The Province filed a complaint for expropriation, marking the initiation of legal proceedings.
- July 11, 1963: An order from Judge Guillermo Dacumos set the provisional value of the property at P1,050.48, allowing the Province to take immediate possession.
- August 27, 1966: A motion from the Province to withdraw the deposit was filed.
- December 9, 1971: The court issued an order determining the fair market value of the expropriated land and consequential damages, totaling P18,137.68, with interest from the date of possession.
- September 14, 1973: A motion for execution was filed to enable the private respondents to receive their payment.
- October 25, 1973: Judge Sixto A. Domondon ordered the approval