G.R. No. 185638 - Vergara vs. Grecia

The case involves a parcel of land covered by Transfer Certificate of Title No. T-101793, measuring 7,420 square meters, located in Barangay Barrera, Cabanatuan City, owned by the respondents.
In 1989, the Sanggunian took the land for road-right-of-way and widening projects but failed to provide just compensation to the respondents.
An appraisal committee was formed to determine the compensation, recommending P2,295.00 per square meter.
A Memorandum of Agreement (MOA) was executed on December 4, 2001, committing the Sanggunian to pay P17,028,900.00 over 12 years, but no payments were made.
The Sanggunian later denied ratification of the MOA due to fiscal constraints, prompting the respondents to file a petition for mandamus in December 2005.

The RTC of Cabanatuan City, Branch 86, ruled in favor of the respondents on September 18, 2006, ordering the petitioners to pay P17,028,900.00 plus interest, attorney's fees, and damages.
The petitioners appealed the decision but sought partial execution of the judgment, leading to an order for them to pay P10,000,000.00 as partial compensation.
The case was reassigned to RTC-Branch 30, which denied the petitioners' motions for reconsideration, leading to a writ of execution and a Notice of Garnishment.

The petitioners filed a Petition for Certiorari with the Court of Appeals, which granted a temporary restraining order against the enforcement of the writ of execution.
The CA ultimately affirmed the RTC's order but modified the compensation amount to P2,554,335.00, representing 15% of the property value.
The petitioners' motion for reconsideration was denied, prompting them to file a petition for review on certiorari.

The petitioners contended that the subject land is a subdivision road, thus beyond the commerce of man, rendering the MOA void and negating any obligation to pay compensation.
They raised issues regarding the authority of Mayor Vergara to sign the MOA and the applicability of estoppel.

The Court found that the petitioners had already lost their appeal in CA-G.R. SP No. 98397, which dismissed their arguments regarding the land's status and the validity of the MOA.
The Court reiterated that the subject land was taken for public use, necessitating just compensation as mandated by the Constitution.
The Court ruled that the petitioners were liable for just compensation, emphasizing that the land was within the commerce of man and thus subject to expropriation.

The Court determined that the respondents were entitled to the full market value of the land, amounting to P17,028,900.00, as the petitioners failed to initiate proper expropriation proceedings.
The Court highlighted that the respondents had been deprived of their property since 1989 without compensation, necessitating a judicial determination of just compensation.

The Court ruled that the delay in payment warranted the imposition of interest, recognizing that just compensation must be made without delay.
Legal interest was set at 12% per annum from the date of the filing of the complaint (December 29, 2005) until July 1, 2013, after whi...continue reading