REPUBLIC OF THE PHILIPPINES (UNIVERSITY OF THE PHILIPPINES), PETITIONER, VS. RODOLFO L. LEGASPI, SR., QUEROBIN L. LEGASPI, OFELIA LEGASPI-MUELA, PURISIMA LEGASPI VDA. DE MONDEJA…

Republic of the Philippines versus Legaspi

The Case

This is a petition for review on certiorari brought by the Republic of the Philippines, through the University of the Philippines in the Visayas, against Rodolfo Legaspi, Senior, and the other registered owners of a parcel of land in Miag-ao, Iloilo. The Republic had filed an action for eminent domain to condemn the property for the university campus, and the question that reaches the Supreme Court is procedural and constitutional at once: whether the trial court's orders refusing to condemn seven of the ten subdivided lots may be corrected by certiorari even though no appeal was taken, and whether those orders are void for failing to state clearly and distinctly the facts and the law on which they rest. The case matters because it fixes the two stages of every expropriation action and reminds every judge that a decision without stated reasons is no decision at all.

Procedural History

The Republic, through the University of the Philippines in the Visayas, filed a complaint for eminent domain before Branch 38 of the Regional Trial Court of Iloilo City. The trial court issued an order of condemnation over three lots, later fixed just compensation for those three lots, and then issued a second order of condemnation over the remaining seven lots while excluding the area occupied by the Villa Marina Beach Resort. On motions for reconsideration, the trial court issued a further order denying the expropriation of all seven remaining lots. The Republic went to the Court of Appeals by a petition for certiorari and mandamus under Rule 65, and the Court of Appeals denied the petition, holding that the proper remedy was an ordinary appeal and that certiorari cannot substitute for a lost appeal. The Republic did not move for reconsideration of that denial and came directly to the Supreme Court by a petition for review on certiorari under Rule 45.

Facts

In December 1978, Rosalina Libo-on signified her willingness to sell to the University a forty thousand one hundred thirty-three square meter parcel in Miag-ao, Iloilo, covered by her original certificate of title. A deed of definite sale was executed for fifty-six thousand four hundred seventy-nine pesos and fifty centavos, and the University immediately took possession and began building roads, infrastructure, and school facilities.

In January 1980, however, Rosalina wrote to the University rescinding the sale, claiming she was no longer the owner because she had earlier conveyed the property by barter or exchange to the Legaspi respondents and others. The University later learned that the lot had been subdivided into ten lots and registered in the names of the respondents.

In August 1991, the University sued for eminent domain, alleging that the property lay within its approved campus and that negotiations had failed. The trial court allowed the University to continue in possession upon a provisional deposit of fifty thousand seventy pesos. The respondents answered that the right of expropriation should cover only three lots with an aggregate area of eight thousand five hundred sixteen square meters. The trial court issued an order of condemnation over those three lots, and later fixed just compensation at fifty-one thousand ninety-six pesos. Over the remaining seven lots, the trial court first upheld expropriation but excluded the beach resort area, and then, on reconsideration, denied expropriation altogether, reasoning that the University's campus would not be impaired without those lots, that the resort and a business called Omp's Corner had operated there before the suit, that one respondent's family would be left without a home, and that a portion served as a public cemetery.

Issues

• Whether or not the Court of Appeals erred in denying the petition for certiorari on the ground that the proper remedy from the trial court's orders was an ordinary appeal.
• Whether or not the trial court's orders denying expropriation of the seven lots were issued with grave abuse of discretion amounting to lack or excess of jurisdiction.
• Whether or not the trial court's orders are void for failing to state clearly and distinctly the facts and the law on which they are based.

Applicable Provisions

Section 14, Article Eight of the Constitution provides:

No decision shall be rendered by any court without expressing therein clearly and distinctly the facts and the law on which it is based.

This is the constitutional standard against which the trial court's orders are measured, and the Court holds that an order failing it is void and legally inexistent.

Section 1, Rule 65 of the Rules of Court, as the decision describes it, provides that a petition for certiorari lies only when there is no appeal, nor any plain, speedy and adequate remedy in the ordinary course of law. This defines the narrow door through which the Republic sought to pass after its appeal period lapsed.

Ruling

On the first issue, the Court ruled that although certiorari cannot generally substitute for a lapsed appeal, the rule has been relaxed where its rigid application would result in a manifest failure or miscarriage of justice, and where the appeal is not adequate or equally beneficial, speedy and sufficient. Certiorari and appeal are not mutually exclusive in exceptional cases, such as when there is grave abuse of discretion or when public welfare so requires.

On the second and third issues, the Court found grave abuse of discretion manifest as early as the order that excluded the beach resort area without giving any rationale therefor. The Court held that the requirement of stating the facts and the law is a component of due process, quoting its earlier ruling:

The parties to a litigation should be informed of how it was decided, with an explanation of the factual and legal reasons that led to the conclusions of the court.

The Court also fixed the structure of expropriation: there are two stages, the condemnation of the property upon a determination of public purpose, and the determination of just compensation with the assistance of not more than three commissioners, and the outcome of each stage is a final order that may be appealed.

Doctrine

First, every expropriation action has two stages: the determination of the authority to exercise eminent domain, ending in an order of condemnation or dismissal, and the determination of just compensation. Each stage ends in a final order, and multiple appeals may arise.

Second, a decision or order that does not clearly and distinctly state the facts and the law on which it is based is void and deemed legally inexistent, for it violates the constitutional mandate quoted above and the due process right of the losing party to know why it lost.

Third, certiorari may be allowed in lieu of a lapsed appeal where there is grave abuse of discretion or where public welfare so requires, since the remedies are not mutually exclusive in exceptional cases.

Disposition

The Court granted the petition, set aside the decision of the Court of Appeals and the challenged orders of the trial court, and upheld the Republic's right to expropriate the remaining seven lots.

Remember This

Memorize the line that a decision not stating clearly and distinctly the facts and the law is void and legally inexistent. Examiners use this case to test the two stages of expropriation, the finality of each stage, and the exception allowing certiorari in place of a lost appeal.