**Republic of the Philippines vs. Vicente G. Lim: A Case on the Finality of Expropriation and the Obligation to Pay Just Compensation**
### Facts:
The Government of the Philippines instituted expropriation proceedings in 1938 for lots in Cebu City to establish a military reservation. Despite taking possession after depositing P9,500 with the Philippine National Bank and a 1940 Court of First Instance (CFI) decision ordering payment of P4,062.10 as just compensation, the government failed to compensate the owners. Decades of effort by the Denzons’ heirs, including legal actions and appeals to government authorities, were fruitless. By 1966, the Supreme Court affirmed that the heirs (Valdehueza and Panerio) retained ownership for lack of compensation but ruled they could only demand fair market value, not property recovery. Valdehueza and Panerio mortgaged Lot 932 to Vicente Lim in 1964, who foreclosed it in 1976 after non-payment, gaining title. Lim sued the Republic and military officers in 1992 to quiet title to Lot 932, leading to a 2001 RTC decision in his favor, which the Court of Appeals affirmed in 2003. The Supreme Court initially denied the Republic’s petition for review in 2004 and eventually addressed the Republic’s motions for reconsideration with emphasis on the procedural and substantive law principles governing eminent domain and just compensation.
### Issues:
1. Whether the Republic retained ownership of Lot 932 despite failing to pay just compensation within a reasonable timeframe.
2. Whether non-payment of just compensation entitles previous landowners to recover possession of expropriated property.
3. The relevance of the procedural prohibition against a second motion for reconsideration.
4. Whether public interest can justify retaining possession without just compensation.
### Court’s Decision:
The Supreme Court emphatically underscored the constitutional mandate that private property cannot be taken for public use without just compensation. It reaffirmed that ownership transfers upon full just compensation, which had not occurred over 57 years. The Court ruled against the Republic, highlighting its failure to follow through on the compensation ordered in 1940 and affirmed in 1966. Remarkably, the Court diverged from its precedent in considering the unique circumstances of the case, allowing for recovery of possession due to the unjustifiable delay in payment.
### Doctrine:
– The pivotal doctrine established is that title and ownership in expropriation cases transfer from the original owner to the expropriator only upon full payment of just compensation, reinforcing the constitutional guarantee against the deprivation of private property without due process and just compensation.
### Class Notes:
– In eminent domain cases, the ownership transfer is contingent on full payment of just compensation.
– Constitutional provision emphasized: “Private property shall not be taken for public use without just compensation.” (Sec. 9, Art. III, Constitution).
– Procedural rule: No second motion for reconsideration shall be entertained (Sec. 2, Rule 52, Rules of Civil Procedure, as amended).
– Just compensation entails both the correct determination and prompt payment of the property’s value.
– The courts may permit recovery of possession if just compensation is delayed unreasonably.
### Historical Background:
This case captures the protracted struggle between private property rights and public use in the Philippines, amidst changing political landscapes from pre-World War II through to the late 20th century. It underscores the challenges in administrative processes and highlights the judiciary’s role in safeguarding constitutional rights against governmental overreach and delay.
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