Title
Republic vs. Court of Appeals
Case
G.R. No. 146587
Decision Date
Jul 2, 2002
Expropriation case: 1969 land acquisition for public use; 1979 compensation fixed at P6/sq.m. with interest. Non-payment led to legal disputes; SC upheld 1979 decision, denied return of property, and ordered payment of just compensation.
expropriation case
prescription
return of expropriated property
A

Case Summary (G.R. No. 97347)

Petitioner’s Allegations and Initial Taking

On 19 September 1969, petitioner instituted expropriation proceedings for a total of 544,980 square meters to continue broadcast operations and radio transmitter facilities for a “Voice of the Philippines” project. Petitioner entered possession after the prior lessee ceased operations and deposited P517,558.80 as the provisional, reasonable value of the property.

Trial Court Judgment of 1979

On 26 February 1979 the Regional Trial Court (RTC) of Bulacan rendered a final judgment condemning the properties, adjudging them taken for the public purpose alleged, and directing payment of just compensation at P6.00 per square meter with legal interest from 19 September 1969 until fully paid. The judgment also ordered payment of costs of suit and commissioners’ fees.

Non‑payment, Enforcement Efforts, and Partial Disbursement

The national government did not timely pay the heirs. Respondents sought enforcement: a manifestation and motion for payment was filed on 9 May 1984; the Bulacan RTC issued a writ of execution on 7 June 1984 after finding P1,058,655.05 unpaid. Subsequent motion urged release of respondents’ share of the original deposit; on 10 July 1984 the court ordered release of P72,683.55 from the provincial treasurer, which respondents received on 23 July 1984.

Subsequent Disposition of the Property by Proclamation

President Estrada issued Proclamation No. 22 transferring 20 hectares of the expropriated property to Bulacan State University and another five hectares for propagation of the Philippine carabao, while the remaining portions were retained by the PIA for development consistent with public purposes.

Renewed Proceedings and RTC’s 2000 Order

Petitioner filed a manifestation on 16 September 1999 offering to deposit P4,664,000.00 as just compensation for the late Luis Santos’s expropriated portion. Respondents opposed and sought adjustment of compensation to current zonal valuation (P5,000/sq.m.) or, alternatively, return of the property. On 1 March 2000 the Bulacan RTC vacated its 1979 decision as unenforceable by reason of prescription under Section 6, Rule 39 of the Rules of Court, denied petitioner’s 1999 motion to deposit, and ordered return of the expropriated property to respondent heirs citing Government of Sorsogon v. Vda. de Villaroya.

Procedural Posture before the Court of Appeals and the Supreme Court

Petitioner elevated the matter to the Court of Appeals, which denied relief, and then to the Supreme Court. The Court of Appeals’ handling was considered in light of Rule 65 procedural amendments (Section 4, Rule 65) and curative amendments clarifying periods to file petitions after motions for reconsideration. The Supreme Court granted review on the substantive public‑interest and legal correctness of the RTC’s vacatur.

Issues Presented

Primary issues decided by the Supreme Court included: (1) whether the 1979 judgment became unenforceable by prescription under Section 6, Rule 39; (2) whether possession, use, and partial payment constituted partial compliance that precluded prescription or otherwise estopped respondents from seeking return of the property; (3) whether respondents could demand reconveyance of condemned property; and (4) whether interest should be computed from the time of taking and the proper legal basis for such interest.

Constitutional and Doctrinal Framework

Eminent domain is an attribute of sovereignty subject to two constitutional constraints: taking must be for public use and just compensation must be paid. Under the 1987 Constitution, just compensation is measured by fair market value at the time of actual taking. The Court treated these constitutional principles as the controlling normative backdrop for resolving competing remedies and claims.

Nature of Expropriation and Effect of Final Judgment

The Court emphasized that condemnation proceedings are in rem and operate upon the property; once a final and executory judgment condemns property, title vests in the public and the affected owner’s remedy is essentially to be paid just compensation, not to recover possession. The Court relied on precedents holding that after final condemnation, owners are not entitled to restitution of possession but only to payment of the fair market value fixed at the time of taking.

Possession, Partial Compliance, and Estoppel

The Court found that petitioner’s occupation and use of the property pursuant to the 1979 judgment amounted to at least partial compliance with that judgment. That exercise of dominion and public use constituted a form of satisfaction of the judgment and mitigated any claim that the 1979 decision had become unenforceable by prescription. The Court rejected respondents’ position treating the small 1984 release from the original deposit as the only relevant act; rather, the condemnor’s continued possession and use were significant in assessing enforceability and equitable considerations.

Prescription, Execution, and Parties’ Responsibility

Section 6, Rule 39 provides that a final and executory judgment may be executed on motion within five years from entry, and thereafter by independent action until barred by the statute of limitations. The Court concluded the RTC erred in declaring the 1979 judgment unenforceable merely because execution by motion was not completed within five years; the RTC’s power was limited to executing its decision. Moreover, the Court observed that respondents themselves delayed filing motions to enforce payment until 1984—five years after finality—and that their delay (laches) undermined the equities of ordering reconveyance.

On Respondents’ Request to Recover Possession

The Court distinguished the present case from cases cited by respondents where reconveyance was permitted for unpaid landowners dealing with local government entities with limited delegated power. Here, the condemnor was a national agency exercising sovereign eminent domain; prior

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