(1) Petitioner Teresita Yujuico filed a petition for review of an RTC decision regarding compensation for her expropriated property used as a school site by the City of Manila for over 5 years.
(2) The RTC granted Yujuico's petition and ordered the City to pay compensation. The City appealed to the Supreme Court.
(3) The Supreme Court upheld the RTC's decision, finding that the City failed to fully compensate Yujuico for her property despite long-term use as a public school. The Court relaxed procedural rules to ensure substantial justice given the circumstances.
(1) Petitioner Teresita Yujuico filed a petition for review of an RTC decision regarding compensation for her expropriated property used as a school site by the City of Manila for over 5 years.
(2) The RTC granted Yujuico's petition and ordered the City to pay compensation. The City appealed to the Supreme Court.
(3) The Supreme Court upheld the RTC's decision, finding that the City failed to fully compensate Yujuico for her property despite long-term use as a public school. The Court relaxed procedural rules to ensure substantial justice given the circumstances.
(1) Petitioner Teresita Yujuico filed a petition for review of an RTC decision regarding compensation for her expropriated property used as a school site by the City of Manila for over 5 years.
(2) The RTC granted Yujuico's petition and ordered the City to pay compensation. The City appealed to the Supreme Court.
(3) The Supreme Court upheld the RTC's decision, finding that the City failed to fully compensate Yujuico for her property despite long-term use as a public school. The Court relaxed procedural rules to ensure substantial justice given the circumstances.
NATURE: Petition for review on certiorari the decision of the RTC Procedural Issues: PONENTE: Tinga, J. COURT (1) On April (3) 6 Mandamus 2001, petitioner is a filed remedy a available Motion forto Execution a propertyofowner Judgment, when a money which the RTC granted. Branch sheriff served a Notice of Garnishment of judgment is rendered in its favor and against a municipality or city; as DOCTRINE: Money claims arising from contracts: filing of an Procedural Issue: funds of the City to satisfy judgment with interest. stated in Municipality of Makati v. Court of Appeals: expropriation case allows the court to have jurisdiction over a local (2) Not having been favored with a reply to her queries even after the lapse of “Nevertheless, this is not to say that private respondent and PSB are government unit Although the Order the 30day compliance period, sent a letter to CSB dated Sept 10, 2001, cannot be madeleft with to subject noanlegal recourse. appeal, the ruleWheremay abemunicipality fails or refuses, demanding and relaxed when exceptional without compliance compelling justifiable with reason, the Order. circumstances She to effect then warrant the payment filed of a for a petition final money RULING FORMAT: exercise of this contempt. judgment rendered Court’s primary jurisdiction. against In this case, theit,judgment the claimant may avail of the remedy RTC – Granted petition of Yujuico. Granted sought to be(3)satisfied has long Finding Order of mandamus attained finalityin and orderthe granting Petition for Relief to from compel the enactment expropriated Judgment and approval of the unacceptable, necessary property has beenpetitioner appealed to the SC by Certiorari. appropriation utilized as a school site for 5 now, yet just compensation ordinance, and the corresponding FACTS has not been fully paid. These circumstances disbursement of municipal merit fundsof the relaxation therefore.” the (4) On Dec 8, 1995, City Council of Manila enacted an Ordinance technical rules of procedure to ensure that substantial justice will be authorizing the City Mayor to acquire by negotiation or served. (4) The source of the amount necessary to acquire petitioner’s property having expropriation certain parcels of land for utilization as a site for the RESPONDENT (City in fact been specified by the City Council of Manila, the passage of the of Manila) Francisco Benitez Elementary School. Substantial Issues: resolution for the allocation and disbursement thereof is a ministerial duty (5) The property chosen is located along Solis St. in Manila, containing Procedural Issues:of the CSB. an approx. area of 3,979.10 square meters. The TCTs are all in the (1) Records of this case clearly show that the same counsel, the OCLO, (1) Invoking jurisprudence holding that public funds cannot be made subject to name of petitioner Teresita Yujuico. represented the City in the expropriation case and now, all except (5) Having relied on the representations of respondents for petitioner to file a garnishment, the City filed a motion to quash the Notice of Garnishment. (6) The Ordinance provides that an amount not to exceed the FMV of one of the individual respondents in the case at bar. Manifestation in (2) Countering Petition for Mandamus, petitioner cannot now be sent by respondents on petition for contempt, respondent filed Motion to Dismiss. the land then prevailing in the area will be allocated out of the the Order on the Motion to Quash Notice of Garnishment over funds another wild goose chase to obtain ultimate recovery of what she is legally Citing Municipality of Makati v CA, respondents asserted that petitioner Special Educated Fund of the City to defray the cost of acquision. of the City stated, “Upon manifestation of the counsel entitled to. should have filed a petition for mandamus for the to force the CSB to pass the (7) Failing to acquire land by negotiation, the City filed a case for plaintiff that it is the City School Board which has the authority to necessary resolution for immediate payment of the balance of just eminent domain against petitioner as owner of the property. pass a resolution allocating funds for the full satisfaction of the just While this Court recognizes the power of LGU to expropriate private compensation awarded in her favor. (8) RTC rendered a Decision in the expropriation case in favor of the compensation fixed.” property for public use, it will not stand idly by while the expropriating (3) Following the decision of the RTC, respondents filed a Petition for Relief City; declaring said lots to be expropriated for public use. In Same counsel who made manifestation now claims that the City authority maneuvers to evade the payment of just compensation of from Judgment, invoking excusable negligence for failure to seasonably exchange, City must pay Yujuico the FMV of the total sum of the should be made liable for payment of its own obligations, after property already in its possession. file an appeal. (This was granted by the RTC, despite attainment of finality subject lots. Judgment became final and executory, no appeal having previously stating of the Decision) that the CSB had authority to satisfy the been interposed by either party. obligation it had The notion of expropriation is hard enough to take for a private owner. He pursued. Through counsel, respondents are Substantive Issues: and courts acted in accordance with the estopped. Petitioner is compelled to give up his property for the common weal. But to give it RTC City’s own manifestations by running after the CSB, therefore, up and wait in vain for the just compensation decreed by the courts is too - Court granted Motion to Quash the Notice of Garnishment, stating that respondents and OCLO can not pass the obligation back to the much to bear. In cases like these, courts will not hesitate to step in to (1) CSB has a personality separate and distinct from the City such that it this case is on all fours with the case of Municipality of Makati v CA, City. should not be made to pay for the City’s obligations. ensure that justice and fair play are served. wherein it was ruled that “Public funds are not subject to levy and (2) Contrary to respondents’ claim, the law does not make the CSB an (2) Members of the CSB cannot be directed to decide a discretionary function execution.” Directed to release the said amount (P31,039,881) to entity independent from the City of Manila. This is evident from the Just compensation means not only correct determination of amount, but in the specific manner the court desires. (Mandamus in this case) Yujuico in partial payment of just compensation. City School Board provisions of the Local Government Code of 1991 and from the ff also payment within reasonable time from its taking. The decision (CSB) is given 30 days to pass resolution for payment of the facts: rendering just compensation in petitioner’s favor was promulgated way remaining balance due to the Yujuico. The highest ranking official of an LGU is designated as co back in the year 2000, years have passed, yet the award still has not been - Court granted petitioner’s Motion for Execution, ordered respondents chairman of the school board fully satisfied. to pass resolution appropriating necessary amount for full and Government officials in the school board do not receive any complete payment of remaining balance due. With respondents not compensation(6) or Republic v Lim: Here the government failed to pay just compensation remuneration while NGO representatives interposing an appeal, Decision became final and executory. merely receive allowances within five (5) years from the finality of judgment in the expropriation - Court subsequently granted respondent’s Petition for Relief from Judgment, despite the attainment of finality of the Decision. proceedings, the owners concerned shall have the right to recover possession of their property. Such is not a remote possibility; WHEREFORE, petition is GRANTED. Order of RTC granting respondents’ Petition for Relief from