Case Summary (G.R. No. 177611)
Background and Property Ownership
In December 1978, respondent Rosalina Libo-on executed a letter of intent and subsequently a Deed of Definite Sale to sell Lot No. 1 to UPV for ₱56,479.50. UPV took immediate possession and developed the property for educational purposes. However, in January 1980, Rosalina rescinded the sale, claiming she had already conveyed the property by barter to the Legaspi respondents. The lot was subdivided and registered under different TCTs in the names of the respondents.
Expropriation Proceedings Initiated by UPV
On August 8, 1991, UPV filed an expropriation suit before the Regional Trial Court (RTC) of Iloilo City, seeking to confirm its right of condemnation and fix just compensation. UPV alleged the property's inclusion in its campus plan and claimed failure of negotiations with respondents. The RTC allowed UPV to continue possession upon depositing a provisional valuation amount. Respondents contested the right to expropriate only part of the subdivided lots.
RTC Orders on Expropriation
The RTC issued an order on April 1, 1992, condemning three lots (Nos. 21609-B, 21609-C, and 21609-E), recognizing UPV’s lawful right to take these lots for public use. UPV later sought to continue condemnation proceedings for the remaining seven lots. In June 2000, the RTC fixed just compensation for the initial three lots at ₱51,096.00.
Dispute Over Remaining Seven Lots
On November 17, 2003, the RTC entered an order allowing UPV to expropriate the seven remaining lots, excluding the area occupied by Villa Marina Beach Resort, operated by respondent Rodolfo Legaspi, Sr. UPV and petitioner moved for reconsideration, alleging that the exclusion was unjustified and contrary to evidence showing the area was part of UPV’s educational development plan. Respondents countered by asserting ownership or occupancy of certain lots and requested exclusion of these from expropriation.
RTC’s Reconsideration Order of May 31, 2004
The RTC granted respondents’ partial motion for reconsideration, denying UPV’s right to expropriate the seven lots based on findings that Villa Marina Beach Resort existed prior to the complaint, some lots were used for business or residence, and one portion served as a public cemetery. The RTC ruled that excluding these lots would not defeat UPV's campus development plan. Consequently, the order appointing commissioners for determining just compensation was set aside.
CA Denial of Rule 65 Petition
UPV filed a Rule 65 petition for certiorari before the Court of Appeals (CA), disputing the RTC’s denial of expropriation rights. The CA denied the petition, ruling that an ordinary appeal was the proper remedy, not a petition for certiorari. The CA further held that the RTC was within its jurisdiction in reviewing and reconsidering prior orders.
Issues Presented
The key legal question raised by UPV was whether the CA erred in denying the petition for certiorari and affirming the RTC’s May 31, 2004 order that failed to state the factual and legal bases for denying UPV's right to expropriate the seven disputed lots.
Nature and Stages of Expropriation Proceedings
The Court emphasized that expropriation proceedings under Rule 67 follow two stages:
- Determination of authority and propriety of expropriation, ending with an order confirming the right to expropriate or dismissal. This order is final and appealable.
- Determination of just compensation to be paid, also subject to appeal separately.
The Court noted jurisprudence recognizing multiple appeals in expropriation cases corresponding to these stages.
Finality of RTC Orders and Appeal Rights
The RTC’s April 1, 1992 order condemning the first three lots was final and unappealed, validating UPV’s right to expropriate those lots. The November 17, 2003 order upheld UPV’s right over the remaining seven lots but excluded the Villa Marina Beach Resort area without explanation. The May 31, 2004 order reversed this in toto, denying UPV’s right to expropriate these lots.
Limitations of Rule 65 and Appropriateness of the Remedy
Although Rule 65 petition for certiorari is generally limited to cases of grave abuse of discretion amounting to lack or excess of jurisdiction and is not a substitute for appeal, the Court acknowledged exceptions to this rule when the remedy of appeal is not adequate, speedy, or sufficient to prevent miscarriage of justice, or when prompt relief is necessary.
Grave Abuse of Discretion by the RTC
The Court found that the RTC’s November 17, 2003 order unlawfully excluded the Villa Marina Beach Resort from expropriation without stating factual or legal grounds, violating Section 14, Article VIII of the 1987 Constitution, which requires judicial decisions to clearly and distinctly state the facts and law on which they are based. This omission prejudiced UPV’s right to due process.
Further, the May 31, 2004 order unjustifiably denied expropriation rights based on respondents’ private use of the land, contrary to constitutional and legal principles that private occupancy or use is not a valid reason to deny expropriation as long as just compensation is paid and the purpose is public use.
The Court also found no documentary evidence that UPV excluded the resort area from expropriation, contrary to the RT
Case Syllabus (G.R. No. 177611)
Facts of the Case
- In December 1978, respondent Rosalina Libo-on expressed willingness to sell Lot No. 1 of Psu-193912 Amd., a 40,133-square meter property in Miag-ao, Iloilo, registered under Original Certificate of Title No. F-20020 in her name.
- A Deed of Definite Sale was executed selling the lot to the University of the Philippines in the Visayas (UPV) for P56,479.50, with UPV immediately taking possession and commencing development works aligned with its educational plans.
- In January 1980, Rosalina rescinded the sale, claiming she had bartered the property to respondents Legaspi family members and others on 5 September 1978.
- The property was subdivided into ten lots (21609-A to 21609-J), registered in the names of various respondents.
- UPV filed an eminent domain complaint on 8 August 1991 seeking to expropriate the entire property due to failed negotiations and citing the campus development, fixing the initial market value at P49,298.00.
- The RTC allowed UPV possession upon deposit of provisional valuation in September 1991.
- Respondents contested UPV's right of expropriation limited only to three lots totaling 8,516 sqm.
- RTC issued an order of condemnation on 1 April 1992 affirming UPV’s right to expropriate those three lots.
- UPV filed for continuation of condemnation for the remaining seven lots and amended its complaint adding mortgage creditors as defendants.
- ROC issued orders fixing just compensation for the three lots at P51,096.00 in June 2000.
- In November 2003, RTC issued an order condemning the remaining seven lots but excluded the part occupied by Villa Marina Beach Resort operated by respondent Rodolfo Legaspi, Sr.
- Motions for reconsideration were filed by both petitioner and respondents, resulting in RTC's May 2004 order denying expropriation of the seven lots, basing denial on existing private business occupancy, residences, and a public cemetery.
- Petitioner filed a Rule 65 petition for certiorari with the Court of Appeals (CA), which was denied in April 2007, prompting the present petition before the Supreme Court.
Issues Presented
- Whether the Court of Appeals erred in denying the Rule 65 petition for certiorari and affirming the RTC order dated 31 May 2004, which failed to state the factual and legal bases of its decision denying UPV the right to expropriate the seven lots.
- Whether the exclusion of the Villa Marina Beach Resort and other lots from expropriation deprived UPV of its lawful right to acquire the property for public use.
- Whether Rule 65 petition for certiorari was the proper remedy instead of an appeal.
Legal Principles and Rules Applied
- Expropriation or eminent domain is an inherent right of the State or lawfully delegated entities to take private property for public use with just compensation.
- Rule 67 of the Rules of Court