DIGEST: SUZEYNE GARCIA /REPUBLIC OF THE PHILIPPINES REPRESENTED BY THE DEPARTMENT OF PUBLIC WORKS AND HIGHWAYS (DPWH) v. HEIRS OF ELIGIO CRUZ, REPRESENTED BY CRISANTA OLIQUINO, AND HEIRS OF ELIGIO CRUZ, REPRESENTED BY MAXIMINO AGALABIA G.R. No. 208956 October 17, 2018

 

REPUBLIC OF THE PHILIPPINES REPRESENTED BY THE DEPARTMENT OF PUBLIC WORKS AND HIGHWAYS (DPWH) v. HEIRS OF ELIGIO CRUZ, REPRESENTED BY CRISANTA OLIQUINO, AND HEIRS OF ELIGIO CRUZ, REPRESENTED BY MAXIMINO AGALABIA

G.R. No. 208956

October 17, 2018

 

FACTS:

 

Sometime in 1977, the Department of Public Works and Highways (DPWH), then Ministry of Public Highways; conducted the widening of Visayas Avenue, Quezon City. The construction encroached upon a 4,757-square meter portion (Disputed Portion) of Lot 643. The Disputed Portion was subdivided, and thereafter registered in the name of the Republic. However, no payment of just compensation was made.

Crisanta Oliquino (Oliquino) filed with the DPWH a claim for payment of just compensation for and on behalf of several heirs of Eligio Cruz, namely, Nieves Cruz, Gregorio Cruz, Ester Cruz-Bernardino and Remigio Cruz (the Oliquino group).

Oliquino demanded just compensation for the Disputed Portion and engaged the services of Atty. Maximo Borja (Atty. Borja) to facilitate the claim. In exchange for Atty. Borja's services, Oliquino executed a Deed of Assignment ceding in his favor the amount of Php14,000,000.00 out of the Php71,355,000.00 she expected to receive from the Republic. However, for reasons not apparent in the records, Oliquino later repudiated the deed, prompting the Republic to release the partial payment of Php39,533,239.13 in Oliquino's favor.

 

Confronted with conflicting claims of ownership over the Disputed Portion of Lot 643 left unpaid, the Republic withheld further payments and demanded the claimants to settle their opposing claims through litigation. Since the claimants failed to do so, the Republic was constrained to file the Interpleader.

A compromise agreement was entered into by the Agalabia, who also claimed just compensation as heir so Eligio Cruze, and Oliquino groups to settle their claims. It was opposed by the De Leon group and Atty. Borja. Notwithstanding such opposition, the RTC issued a Partial Judgment Based on Compromise Agreement. The motions for reconsideration filed by the De Leon group and Atty. Borja were denied by the RTC. The RTC ruled in favor of the Oliquino and Agalabia groups and granted their motion for execution.

 

The Republic filed several motions to avert execution which the RTC denied for lack of merit.

 

The Republic filed before the CA a Petition for Certiorari with Prayer for Issuance of Writ of Preliminary Injunction and Temporary Restraining Order (petition for certiorari). Said petition for certiorari imputed grave abuse of discretion to the RTC.

 

In said petition for certiorari, the Republic averred that the orders directing the execution of the Partial Judgment are premature and were issued without legal basis, since the Partial Judgment “did not adjudicate nor settle the conflicting adversarial claims of the other impleaded defendants who are not parties to the Compromise Agreement,” namely, Atty. Borja and the De Leon group.

 

The CA dismissed the Republic’s petition for certiorari and subsequent motion for reconsideration. The Republic then filed the present petition.

 

ISSUE:

WON the orders directing the execution of the Partial Judgment are premature and were issued without legal basis, since the Partial Judgment “did not adjudicate nor settle the conflicting adversarial claims of the other impleaded defendants who are not parties to the Compromise Agreement”.

 

RULING:

            Yes, the orders directing the execution of the Partial Judgment are premature and were issued without legal basis, since the Partial Judgment did not adjudicate nor settle the conflicting adversarial claims of the other impleaded defendants who are not parties to the Compromise Agreement.

 

The Compromise Agreement divides the Republic's entire remaining balance between and among the defendants, in accordance with the terms agreed upon by the Oliquino and Agalabia groups. The allocation of the remaining balance was determined without the participation of all other claimants who likewise stand as parties to the Interpleader.

 

Clearly, the immediate execution of the Partial Judgment approving the Compromise Agreement facilitates the premature distribution of the Republic's remaining balance without affording the De Leon group and Atty. Borja of the opportunity to establish their entitlement, if any, to compensation beyond the amounts unilaterally set by the Oliquino and Agalabia groups. This defeats the very purpose for which the Republic's Interpleader had been filed, as it opens the portals to protracted litigation not only among the opposing claimants, but also between said claimants and the Republic.