Case Summary (G.R. No. 168716)
Procedural Background
The petitioner, Republic of the Philippines, filed a petition for review on certiorari and prohibition challenging the Decision and Resolution from the Court of Appeals (CA) affirming the Regional Trial Court (RTC) Order that granted Tetro Enterprises, Inc.'s motion to admit an amended complaint. Initially, Tetro Enterprises filed a Complaint for recovery of possession and damages, asserting ownership over a land that the petitioner had utilized for public road construction without proper legal formality or compensation.
Factual Allegations
Tetro Enterprises asserted ownership of a 12,643 square meter lot in San Fernando, Pampanga, and alleged that the petitioner unlawfully constructed a road on it in 1974, thereby depriving it of possession. Despite numerous demands for the return of the property and payment for its use, the petitioner remained unresponsive. The respondent sought the return of the property and damages amounting to P100,000.00, monthly rentals of P200.00, and attorney’s fees.
Developments in the Case
The RTC, recognizing the impracticality of returning the land, converted the possession action into an eminent domain case. A Board of Commissioners was appointed to determine just compensation, culminating in a decision fixing the compensation at P6,000.00 per square meter—a total of P75,858,000.00. This decision faced several challenges through appeals, ultimately being modified by the CA to a total of P252,869.00, plus accrued interest, and remanding the case for damages related to loss of use.
Controversy Surrounding the Amended Complaint
As the case progressed into a phase for determining damages, Tetro Enterprises sought to amend its complaint to increase its demands based on a professional appraisal for damages while citing the need to adjust for economic conditions over the years. The RTC initially approved this amendment amid opposition from the petitioner, claiming a substantial increase in the claims raised by Tetro Enterprises was unjust and inappropriate at such a late stage.
Court of Appeals’ Ruling
The CA upheld the RTC's admission of the amended complaint, affirming that the amendment fell under permissible amendments as specified in the Rules of Court. The CA concluded that the amendment related directly to the proper characterization of damages owed to Tetro Enterprises due to their deprivation of property use since 1974.
Supreme Court's Position
Upon review, the Supreme Court ruled that the CA erred in finding that the RTC exhibited no grave abuse of discretion. The Court clarified that the procedural shift from a recovery of possession to an expropriation case did not warrant amendments as if the original case was still open for changes. The original purpose of remand was so
...continue readingCase Syllabus (G.R. No. 168716)
Case Background
- The case involves a petition for review on certiorari and prohibition regarding the Decision dated November 29, 2007, and the Resolution dated May 8, 2008, from the Court of Appeals (CA) in CA-G.R. SP No. 97784.
- The CA affirmed the Regional Trial Court (RTC) Order dated September 22, 2006, which granted Tetro Enterprises, Inc. (respondent) the motion to admit an amended complaint and subsequently denied the motion for reconsideration.
Antecedent Facts
- On February 10, 1992, Tetro Enterprises, Inc. filed a complaint for recovery of possession and damages against the Republic of the Philippines, represented by the DPWH, in RTC San Fernando, Pampanga (Civil Case No. 9179).
- The respondent claimed ownership of a 12,643 square meter lot in Barangay San Jose, Pampanga, under Transfer Certificate of Title No. 283205-R, with a value of P252,869.00.
- The complaint alleged that, in 1974, the DPWH constructed a road on the subject lot without legal expropriation, depriving the respondent of possession without due process.
Relief Sought
- The respondent prayed for the return of the subject lot to its original state, closure of the road, and payment of actual damages totaling P100,000.00, rental fees amounting to P40,800.00, and attorney's fees.
Petitioner’s Defense
- The petitioner contended there was no cause of action, claiming that the State had not consented to be sued and that the construction was done with the respondent's knowledge and consent.
- The RTC converted the action to eminent domain as recovery of the lot was no longer feasible.
Board of Commissioners
- The RTC established a Board of Commissioners to determine the a