Bardillon vs. Barangay Masili of Calamba, Laguna
The petition assailing the Court of Appeals' dismissal of the certiorari petition was denied. The Supreme Court affirmed that expropriation suits are incapable of pecuniary estimation, vesting jurisdiction exclusively in the regional trial court regardless of the subject property's value. Consequently, the municipal trial court's dismissal of the initial expropriation complaint did not operate as res judicata to bar the subsequent complaint filed before the regional trial court, as the former court lacked jurisdiction. The issuance of the writ of possession was upheld, the expropriating entity having complied with the jurisdictional deposit requirements, and forum shopping was ruled out due to the absence of litis pendentia.
Primary Holding
An expropriation suit is incapable of pecuniary estimation and falls within the exclusive jurisdiction of regional trial courts, regardless of the value of the subject property.
Background
Barangay Masili of Calamba, Laguna sought to expropriate a 144-square meter parcel of land (Lot 4381-D) owned by Devorah E. Bardillon for the construction of a multi-purpose hall. After negotiations for the purchase of the property for P200,000.00 failed, the Barangay initiated expropriation proceedings.
History
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Filed first Complaint for eminent domain before the Municipal Trial Court (MTC) of Calamba, Laguna (Civil Case No. 3648).
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MTC dismissed Civil Case No. 3648 for lack of interest due to plaintiff's failure to appear at pre-trial; Motion for Reconsideration denied.
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Filed second Complaint for eminent domain before the Regional Trial Court (RTC) of Calamba, Laguna (Civil Case No. 2845-99-C).
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RTC denied petitioner's Motion to Dismiss and subsequently issued an Order directing the issuance of a Writ of Possession.
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Filed Petition for Certiorari before the Court of Appeals (CA-GR SP No. 61088).
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CA dismissed the Petition for lack of merit and denied the Motion for Reconsideration.
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Filed Petition for Review on Certiorari before the Supreme Court.
Facts
- The Subject Property: Devorah E. Bardillon acquired Lot 4381-D, a 144-square meter parcel of land in Barangay Masili, Calamba, Laguna, from Makiling Consolidated Credit Corporation via a Deed of Absolute Sale on October 7, 1996.
- First Expropriation Suit: Barangay Masili offered to purchase the lot for P200,000.00. Upon failure to reach an agreement, the Barangay filed a Complaint for eminent domain before the MTC of Calamba on February 23, 1998, docketed as Civil Case No. 3648. The MTC dismissed the case on March 5, 1999, "for lack of interest" due to the Barangay and its counsel's failure to appear at the pre-trial. The MTC denied the subsequent Motion for Reconsideration.
- Second Expropriation Suit: On October 18, 1999, Barangay Masili filed a second Complaint for eminent domain before the RTC of Calamba, Laguna (Branch 37), docketed as Civil Case No. 2845-99-C, seeking the expropriation of the same lot for a multi-purpose hall.
- RTC Proceedings: Bardillon filed a Motion to Dismiss, arguing that the action was barred by res judicata due to the MTC dismissal. The RTC denied the motion on January 21, 2000, holding that the MTC lacked jurisdiction over expropriation proceedings. Following the approval of Municipal Ordinance No. 2000-261 on July 10, 2000, authorizing the expropriation, the RTC issued an Order on August 4, 2000, favoring Barangay Masili, and subsequently issued a Writ of Possession on August 16, 2000.
Arguments of the Petitioners
- Jurisdiction of the MTC: Petitioner argued that the MTC had jurisdiction over the expropriation case because the assessed value of the land was only P11,448, which is within the MTC's jurisdictional threshold.
- Res Judicata: Petitioner contended that the MTC's dismissal of the first Complaint was with prejudice, as there was no indication to the contrary in the dismissal order; thus, the second Complaint before the RTC should be dismissed on the ground of res judicata.
- Legality of Entry: Petitioner asserted that the CA erred in ignoring the RTC's issuance of the Writ of Possession despite a pending Motion for Reconsideration regarding the dismissal of the Complaint.
- Alternative Property: Petitioner maintained that there was an existing multi-purpose hall erected on land owned by Eugenia Almazan, which should be the subject of expropriation instead.
- Forum Shopping: Petitioner claimed that respondent was guilty of forum shopping for seeking another forum after obtaining an unfavorable decision from the MTC.
Arguments of the Respondents
- Jurisdiction of the RTC: Respondent maintained that the RTC had jurisdiction over the expropriation case, as the assessed value of the property was P28,960, exceeding the P20,000 jurisdictional limit of the MTC, and further, expropriation suits are incapable of pecuniary estimation.
- No Res Judicata: Respondent argued that the MTC dismissal did not constitute res judicata because the MTC lacked jurisdiction over the subject matter.
- Propriety of Writ of Possession: Respondent asserted that the Writ of Possession was properly issued upon compliance with the deposit requirements under Rule 67 of the Rules of Court and Section 19 of the Local Government Code.
Issues
- Jurisdiction over Expropriation: Whether the Municipal Trial Court had jurisdiction over the expropriation case based on the assessed value of the property.
- Res Judicata: Whether the dismissal of the first expropriation complaint by the MTC constituted res judicata barring the second complaint before the RTC.
- Legality of Entry: Whether the CA erred in upholding the RTC's issuance of the Writ of Possession despite a pending Motion for Reconsideration.
- Forum Shopping: Whether the respondent was guilty of forum shopping by filing the second complaint before the RTC after the first complaint was dismissed by the MTC.
Ruling
- Jurisdiction over Expropriation: Jurisdiction over expropriation suits lies exclusively with the regional trial courts. An expropriation suit does not involve the recovery of a sum of money but deals with the government's exercise of its authority to take property for public use; thus, it is incapable of pecuniary estimation. The determination of just compensation is merely incidental to the main action.
- Res Judicata: The doctrine of res judicata finds no application because the MTC lacked jurisdiction over the subject matter. One of the essential requisites of res judicata is that the court rendering the judgment must have had jurisdiction over the subject matter and the parties.
- Legality of Entry: The issuance of the Writ of Possession was proper and in accordance with Section 2 of Rule 67 of the Rules of Court and Section 19 of the Local Government Code. The requisites for immediate entry—the filing of a sufficient complaint and the deposit of 15% of the fair market value based on the current tax declaration—were satisfied. Objections to the necessity of the expropriation must be raised in the Answer to the Complaint and determined by the RTC in the course of the proceedings.
- Forum Shopping: Forum shopping does not exist. The test for forum shopping is whether the elements of litis pendentia are present, such that a final judgment in one case would amount to res judicata in another. The earlier MTC case had already been dismissed, precluding litis pendentia. Even if both were pending, a judgment from the MTC, a court lacking jurisdiction, could not constitute res judicata in the RTC.
Doctrines
- Jurisdiction over Expropriation Suits — An expropriation suit is incapable of pecuniary estimation because its primary consideration is whether the government has complied with the requisites for taking private property, not the recovery of a sum of money. The determination of just compensation, though estimated in monetary terms, is merely incidental. Accordingly, regional trial courts have exclusive jurisdiction over expropriation proceedings regardless of the assessed value of the property.
- Res Judicata — A final judgment on the merits rendered by a court of competent jurisdiction is conclusive as to the rights of the parties and constitutes an absolute bar to subsequent actions involving the same claim. The requisites are: (1) the former judgment must be final; (2) the court that rendered it had jurisdiction over the subject matter and the parties; (3) it is a judgment on the merits; and (4) there is an identity of parties, subject matter, and cause of action. The doctrine does not apply if the court rendering the first judgment lacked jurisdiction over the subject matter.
- Issuance of Writ of Possession in Expropriation — In expropriation proceedings, immediate entry upon the property is authorized upon: (1) the filing of a complaint for expropriation sufficient in form and substance; and (2) the deposit of the amount equivalent to 15% of the fair market value of the property based on the current tax declaration. For local government units, this is mandated by Section 19 of the Local Government Code.
Key Excerpts
- "An expropriation suit does not involve the recovery of a sum of money. Rather, it deals with the exercise by the government of its authority and right to take property for public use. As such, it is incapable of pecuniary estimation and should be filed with the regional trial courts."
- "True, the value of the property to be expropriated is estimated in monetary terms, for the court is duty-bound to determine the just compensation for it. This, however, is merely incidental to the expropriation suit. Indeed, that amount is determined only after the court is satisfied with the propriety of the expropriation."
Precedents Cited
- Barangay San Roque v. Heirs of Francisco Pastor — Followed. Reiterated the doctrine that expropriation suits are incapable of pecuniary estimation and fall under RTC jurisdiction, as the primary consideration is the government's exercise of eminent domain, not the property's monetary value.
- Republic of the Philippines v. Zurbano — Followed. Established that condemnation proceedings are within the jurisdiction of Courts of First Instance (now RTCs), as actions incapable of pecuniary estimation.
Provisions
- Section 19(1), Batas Pambansa Blg. 129 (The Judiciary Reorganization Act of 1980), as amended by Republic Act No. 7691 — Defines the jurisdiction of Regional Trial Courts to include all civil actions in which the subject of the litigation is not capable of pecuniary estimation. Applied to vest exclusive jurisdiction over expropriation suits in the RTC.
- Section 2, Rule 67 of the 1997 Rules of Civil Procedure — Governs the entry of the plaintiff upon the property subject of expropriation upon deposit of the assessed value with an authorized government depositary. Applied to validate the RTC's issuance of the Writ of Possession.
- Section 19, Republic Act No. 7160 (Local Government Code) — Authorizes local government units to exercise the power of eminent domain and allows immediate possession upon filing the expropriation proceedings and depositing at least 15% of the fair market value of the property based on the current tax declaration. Applied to uphold the Barangay's right to immediate possession.
Notable Concurring Opinions
Puno, Sandoval-Gutierrez, Corona, and Carpio Morales, JJ.