Republic vs. Legaspi

An order denying the right to expropriate is void and may be annulled via certiorari where the trial court entirely disregards the evidence on record and bases its denial on the private use of the property by the owners, which is not a valid ground to defeat eminent domain exercised for a public purpose.

In December 1978, Rosalina Libo-on executed a Deed of Definite Sale in favor of the University of the Philippines in the Visayas (UPV) for a 40,133-square meter property in Miag-ao, Iloilo. UPV immediately took possession and constructed academic facilities thereon. In January 1980, Libo-on rescinded the sale, claiming she had bartered the property to the Legaspis in September 1978. The property was subsequently subdivided into ten lots and registered in the respondents' names.

• The Sale and Rescission: Rosalina Libo-on sold the 40,133-square meter property to UPV in December 1978. UPV took possession and built road networks and school facilities. In January 1980, Libo-on informed UPV of her rescission of the sale, claiming she had conveyed the property to the Legaspis via barter in September 1978. The property was subdivided into ten lots and registered in the respondents' names.
• The Expropriation Suit: In August 1991, UPV filed an eminent domain complaint. Respondents opposed the expropriation of seven of the ten lots. The RTC condemned the three unopposed lots in April 1992 and fixed just compensation for them in June 2000.
• The Assailed Orders: In November 2003, the RTC issued a condemnation order covering the remaining seven lots but excluded the area occupied by the Villa Marina Beach Resort. Both parties moved for reconsideration. Petitioner sought the inclusion of the resort, while respondents sought the exclusion of additional areas, including a business called Omp's Corner, a public cemetery, and a residential lot. In May 2004, the RTC denied the expropriation of all seven lots, reasoning that excluding them would not impair UPV's operations, the lots were already used for private businesses and residences, and taking the cemetery lot would violate revered customs.

• Propriety of Certiorari: Petitioner argued that certiorari was proper despite the availability of appeal because the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction.
• Grave Abuse of Discretion: Petitioner maintained that the RTC arbitrarily excluded the Villa Marina Beach Resort without basis and erroneously denied the expropriation of the seven lots based on their private use, which is immaterial to the exercise of eminent domain.

• Propriety of Certiorari: Respondent countered that certiorari cannot substitute for a lost appeal, insisting the RTC order was appealable.
• Validity of Exclusion: Respondent argued that the excluded areas were already utilized for existing businesses, a public cemetery, and a family residence, and that their exclusion would not impair UPV's operations.

• Propriety of Certiorari: Whether a petition for certiorari under Rule 65 is the proper remedy to challenge the RTC's denial of expropriation, notwithstanding the availability of an ordinary appeal.
• Grave Abuse of Discretion in Exclusion: Whether the RTC committed grave abuse of discretion in excluding the Villa Marina Beach Resort from the condemnation order without stating the factual and legal bases therefor.
• Grave Abuse of Discretion in Denial: Whether the RTC committed grave abuse of discretion in entirely denying the expropriation of the remaining seven lots on the ground that they were already used for private purposes.

• Propriety of Certiorari: Certiorari was upheld as a proper remedy. While generally an inappropriate substitute for a lapsed appeal, certiorari is allowed where the rigid application of the rule would result in a manifest failure or miscarriage of justice, or where the lower court acted with grave abuse of discretion.
• Grave Abuse of Discretion in Exclusion: The RTC's exclusion of the resort area was void for violating Section 14, Article VIII of the Constitution. The order failed to clearly and distinctly state the facts and the law on which the exclusion was based, leaving the parties in the dark and preventing meaningful appellate review.
• Grave Abuse of Discretion in Denial: The RTC gravely abused its discretion in denying the expropriation of the seven lots. The rationale that the lots were already used for private businesses or residences is not a valid ground to defeat eminent domain, which is a compulsory sale for public purpose upon payment of just compensation. Furthermore, the RTC's finding that the exclusion would not impair UPV's operations was contrary to the evidence on record, which showed the resort site was earmarked for a proposed National Institute of Marine Biotechnology.

• Two Stages of Expropriation — Expropriation proceedings consist of two stages: (1) the condemnation of the property upon determination of public use, and (2) the determination of just compensation. An order of dismissal or condemnation in the first stage is final and appealable; similarly, the order fixing just compensation in the second stage is final and appealable. Multiple appeals are thus recognized in expropriation cases.
• Constitutional Mandate on Decisions (Art. VIII, Sec. 14) — No decision shall be rendered by any court without expressing clearly and distinctly the facts and the law on which it is based. A decision that fails to conform to this requirement is void and legally inexistent, as it deprives the losing party of due process and the ability to pinpoint errors for review.
• Private Use Does Not Defeat Eminent Domain — The fact that property is currently utilized for private purposes (businesses, residences) is not a valid reason to deny the exercise of the right of expropriation, provided the taking is for a public purpose and just compensation is paid.

• "Faithful adherence to the requirements of Section 14, Article VIII of the Constitution is indisputably a paramount component of due process and fair play... A decision that does not clearly and distinctly state the facts and the law on which it is based leaves the parties in the dark as to how it was reached and is precisely prejudicial to the losing party, who is unable to pinpoint the possible errors of the court for review by a higher tribunal."
• "The fact that said lots are being utilized by respondents Legaspis for their own private purposes is, consequently, not a valid reason to deny exercise of the right of expropriation, for as long as the taking is for a public purpose and just compensation is paid."

• Municipality of Biñan v. Judge Garcia, 259 Phil. 1058 (1989) — Followed. Established the two-stage nature of expropriation proceedings and the finality of orders in each stage.
• Yao v. Court of Appeals, 398 Phil. 86 (2000) — Followed. Elaborated on the constitutional requirement for courts to state the facts and law on which decisions are based, declaring decisions that fail to do so as void.
• SMI Development Corporation v. Republic of the Philippines, G.R. No. 137537 (2000) — Followed. Upheld the relaxation of the rule against using certiorari as a substitute for appeal when public welfare requires or grave abuse of discretion is present.

• Section 14, Article VIII, 1987 Constitution — Mandates that no decision shall be rendered by any court without expressing clearly and distinctly the facts and the law on which it is based. Applied to strike down the RTC's November 2003 order for lacking any rationale for the exclusion of the resort area.
• Rule 67, 1997 Rules of Civil Procedure — Governs expropriation proceedings. Applied to delineate the two stages of the suit and the appealability of orders issued therein.
• Rule 65, 1997 Rules of Civil Procedure — Governs certiorari. Applied exceptionally as a remedy despite the availability of appeal, due to the grave abuse of discretion by the RTC.

Carpio (Chairperson), Brion, Sereno, Reyes