Case Summary (G.R. No. 166964)
Legal Proceedings and Context
On April 3, 1987, the NHA initiated eminent domain proceedings against the petitioners for several lots in Tondo, totaling 66,783.40 square meters with an aggregate valuation of ₱21,024,136.50. Instead of responding to the complaint, the petitioners filed motions to dismiss, seeking damages and attorney fees. The NHA, acknowledging these claims, deposited ₱21,107,485.07 with the Philippine National Bank (PNB) as provisional just compensation on March 11, 1988.
Dismissal of the Complaint
On March 11, 1991, the Regional Trial Court ruled in favor of the petitioners, dismissing NHA's complaint. This dismissal was subsequently affirmed by the Court of Appeals on February 26, 1993. On July 26, 1993, the Supreme Court declared the case terminated due to NHA's failure to timely file a petition for review.
Motions for Withdrawal of Deposit
On September 7, 2000, after a seven-year inactivity concerning any claims for damages, NHA filed a motion to withdraw the deposit but did not schedule a hearing. Following a second motion that properly set a hearing date for November 10, 2000, the trial court expunged the first motion and ruled that the amount deposited was an advance payment against future expropriation or indemnity for any damages.
Court of Appeals Decision
Upon appeal, the Court of Appeals reversed the trial court's November 8, 2000 order, allowing NHA to withdraw the deposited funds. The Court held that the petitioners could not present evidence of damages, as their counterclaim had been dismissed along with NHA's initial complaint, limiting their ability to litigate the issue of damages.
Legal Issues Raised by Petitioners
The petitioners contended that the Court of Appeals was guilty of grave abuse of discretion by permitting NHA to withdraw the deposit without a hearing to ascertain damages. The petition articulated two main issues: (1) the lack of notice of hearing for NHA's initial motion, which they viewed as a procedural flaw and (2) the procedural impropriety of allowing NHA to withdraw the deposit prior to a hearing on damages.
Supreme Court's Evaluation
The Supreme Court found the petitioners' arguments to be without merit. The Court emphasized that per Rule 67 of the Rules of Court, the process of eminent domain involves two distinct phases: a condemnation phase followed by an ascertainment of just compensation. Since the initial complaint had been dismissed based on the finding that its acquisition was not for public use, the c
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Case Overview
- This case involves a petition for review on certiorari filed by petitioners against the National Housing Authority (NHA) seeking to overturn the Court of Appeals' decisions dated March 25, 2004, and February 4, 2005.
- The core of the dispute arises from the NHA's attempt to expropriate several lots owned by the petitioners in Tondo, Manila, with a total area of 66,783.40 square meters and an aggregate value of P21,024,136.50.
Background of the Case
- On April 3, 1987, the NHA filed a complaint for eminent domain against the petitioners, who responded with motions to dismiss, seeking damages and attorney’s fees instead of filing an answer.
- The trial court, on March 11, 1988, allowed the deposit of P21,107,485.07 by NHA as provisional just compensation.
- On March 11, 1991, the trial court dismissed the NHA's complaint for expropriation, stating it was not for a public purpose, and also dismissed the petitioners' counterclaims for damages.
Court Proceedings
- The dismissal by the trial court was affirmed by the Court of Appeals in February 1993, and the decision became final and executory on July 26, 1993, due to NHA's failure to file a t