Title
Republic vs. Legaspi, Sr.
Case
G.R. No. 177611
Decision Date
Apr 18, 2012
UPV sought to expropriate land for campus development, but RTC denied expropriation of seven lots, excluding a beach resort. SC reversed, citing RTC's grave abuse of discretion and failure to justify its decision, remanding for proper resolution.

Case Summary (G.R. No. 177611)

Factual Background and Transactions

In December 1978 respondent Rosalina executed a letter of intent and an undated Deed of Definite Sale conveying Lot No. 1 to UPV; UPV took possession and developed facilities. Rosalina later claimed she had conveyed the property earlier by barter/exchange to members of the Legaspi family. The original lot was subdivided into ten lots and registered to respondents. UPV asserted the property was within its approved campus, had built improvements, and sought condemnation when negotiations failed.

Procedural History in the RTC

UPV filed the expropriation complaint (Civil Case No. 19921) in August 1991. The RTC allowed UPV to continue possession upon deposit of a provisional valuation. Because respondents limited expropriation to three of the ten lots, the RTC issued an April 1, 1992 order condemning and confirming UPV’s right to expropriate Lots 21609-B, -C and -E (total 8,516 sq. m.). Later the RTC addressed the remaining seven lots. On June 16, 2000 the RTC fixed just compensation for the three lots at P51,096.00 (crediting earlier deposit). On November 17, 2003 the RTC issued a condemnation order upholding UPV’s right to expropriate the remaining seven lots but excluded from the taking the area occupied by Villa Marina Beach Resort operated by respondent Rodolfo L. Legaspi, Sr. Motions for reconsideration were filed by both sides. On May 31, 2004 the RTC partially reconsidered and denied expropriation of the seven lots (21609-A, -D, -F, -G, -H, -I and -J), and set aside its appointment of provincial officials as commissioners.

Issues Presented on Petition for Review

Petitioner challenged the CA’s April 26, 2007 decision which denied petitioner’s Rule 65 petition for certiorari and mandamus and affirmed the RTC’s May 31, 2004 order. Petitioner’s primary contention was that the RTC’s May 31, 2004 order “did not state the facts and the law on which it is based,” contrary to constitutional requirements.

Legal Framework on Expropriation (Rule 67) and Finality

The Court reiterated that expropriation proceedings under Rule 67 consist of two stages: (1) determination of the plaintiff’s authority and propriety to exercise eminent domain (ends with an order of condemnation or dismissal), and (2) determination of just compensation with commissioners’ assistance. Orders in each stage are final as to that stage and are appealable; multiple appeals may therefore arise from an expropriation case because of its two-stage nature.

RTC’s Orders and Reasons Found Deficient

The RTC’s November 17, 2003 order upheld UPV’s right to expropriate the seven lots but excluded the Villa Marina Resort area without stating rationale. The May 31, 2004 order then denied expropriation of those seven lots, citing that portions were being used by respondents for business or residence, a portion served as a public cemetery, and that excluding those areas would not impair UPV’s campus. The RTC’s May 31, 2004 decretal portion denied expropriation and rescinded the commissioners’ appointment.

CA’s Ruling and the Question of Proper Remedy

The CA denied the Rule 65 petition on the ground that certiorari cannot substitute for an ordinary appeal; Rule 65 lies only where there is no appeal or any plain, speedy and adequate remedy. The CA held that the proper remedy from the RTC orders was an ordinary appeal, and certiorari was inappropriate.

Supreme Court’s Analysis on Certiorari Exception and Grave Abuse

The Supreme Court recognized the general rule that certiorari is narrow and limited to jurisdictional errors or grave abuse of discretion, and ordinarily not a substitute for appeal. However, it recalled jurisprudence relaxing that rule where strict application would result in manifest failure or miscarriage of justice, or where appeal is not adequate, speedy or sufficient. The Court found that the RTC’s issuance of the two assailed orders involved grave abuse of discretion—conduct equivalent to lack of jurisdiction—warranting relief by certiorari despite availability of appeal.

Supreme Court’s Findings on Constitutional Violation (Section 14, Art. VIII)

The Court found the RTC violated Section 14, Article VIII of the 1987 Constitution by issuing decisions that failed to state clearly and distinctly the facts and the law on which they were based. The November 17, 2003 order excluded the Villa Marina area without explanation and the May 31, 2004 order denied expropriation on impermissible grounds without adequate factual or legal basis. The Court emphasized that due process requires parties be informed of how a case was decided and the factual and legal reasons supporting the decision; a decision lacking those elements i

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