Case Summary (G.R. No. 82761)
Relevant Dates and Proceedings
The expropriation proceedings began with a complaint filed by the DPWH on February 2, 1999. The Regional Trial Court (RTC) of Cagayan de Oro City issued an Order of Expropriation on November 27, 2000, and subsequently allowed the Republic to take possession of the property on November 29, 2000. A resolution determining just compensation was issued on January 21, 2010. The subsequent execution of judgment led to disputes over the computation of the remaining balance, culminating in extensive litigation that included an Order dated June 25, 2014, which fixed the interest rate at 12% per annum for just compensation.
Applicable Law
The legal framework primarily revolves around the principles enshrined in Section 9, Article III of the 1987 Philippine Constitution, which mandates that no property shall be taken for public use without just compensation. Jurisprudence establishes that just compensation includes the proper interest on any unpaid amounts.
Issues and Arguments
The central issue in this case is whether the RTC erred in imposing 12% legal interest on the remaining just compensation due to Tamparong. The Republic contended that it had made substantial provisional payments and, therefore, argued that the imposition of interest was unwarranted. Conversely, Tamparong argued for the appropriate legal interest based on prevailing jurisprudence, contrasting the DPWH's computation that proposed a lower interest rate.
Court’s Findings
The Court ruled in favor of Tamparong, affirming the RTC's imposition of 12% interest on the unpaid balance of just compensation. The ruling echoed the jurisprudential standard that determines just compensation must include legal interest, particularly when a delay in payment occurs. The Court emphasized that failure to provide complete payment at the time of property taking incurs legal interest owed to the landowner as compensation for the delay.
The Court highlighted that while provisional payments were made, they did not absolve the Republic of its obligation to compensate the landowner fully, including accruing legal interest from the date of taking until payment is satisfied. A distinction was made between the initial compensatio
...continue readingCase Syllabus (G.R. No. 82761)
Background and Procedural History
- The case involves an expropriation proceeding initiated by the Department of Public Works and Highways (DPWH) against Casimiro Tamparong, Jr., concerning a 7,555-square meter parcel of land in Barangay Kauswagan, Cagayan de Oro City, intended for the Cagayan de Oro Third Bridge and Approaches project.
- On November 27, 2000, the RTC Branch 24 issued an Order of Expropriation declaring the Republic's lawful right to take the property for public use.
- On November 29, 2000, the same RTC branch issued an Order granting immediate possession of the property to the Republic.
- The determination of just compensation went through extensive hearings and pleadings before RTC Branch 20.
- The RTC, Branch 20, in a Resolution dated January 21, 2010, fixed the just compensation at PHP 3,500 per square meter, totaling PHP 26,442,500, less the provisional deposit of PHP 9,443,750 already paid, with legal interest from the taking of possession until payment is made, at 12% per annum.
- The Resolution became final and executory as no appeal or motion for reconsideration was filed.
- Subsequent controversy arose over the computation of the remaining balance at the execution stage, leading to the issuance of writs of execution and orders modifying the amount to be paid.
Controversies on Computation of Just Compensation and Interest
- The DPWH submitted a computation including interest at 6% per annum from the taking of the property and 12% per annum from the finality of judgment until December 11, 2013.
- Tamparong’s counsel requested immediate payment, subject to adjustment of interest to the actual date of full satisfaction due to Tamparong’s advanced age and medical condition.
- Tamparong filed a Motion for Recomputation demanding 12% interest per annum from the taking of the property to conform with prevailing jurisprudence.
- RTC Branch 20 ruled on June 25, 2014, fixing the legal interest rate at 12% per annum from the date of the January 21, 2010 resolution until full payment, less the provisional deposit already paid.
- The Republic argued in a Motion for Reconsideration that the imposition of 12% interest was unwarranted since it had made substantial provisional payments and there was no delay.
- The Motion for Reconsideration was denied, thus prompting a Petition for Certiorari before the Court of Appeals (CA), which affirmed the RTC's order.
Issues Presented
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