G.R. No. 54281, March 19, 1990
CELSO PAGTALUNAN and PAULINA P. PAGTALUNAN, petitioners, vs. HON. ROQUE A. TAMAYO, Presiding Judge of the CFI of Bulacan, Branch VI, REPUBLIC OF THE PHILIPPINES and TURANDOT, TRAVIATA, MARCELITA, MARLENE PACITA, MATTHEW and ROSARY, all surnamed ALDABA, respondents.

FACTS

The Republic of the Philippines filed a complaint for expropriation of a parcel of land in Malolos, Bulacan, registered under TCT No. 24006 in the names of the private respondents, the Aldabas. The Court of First Instance issued a writ of possession. Petitioners Celso and Paulina Pagtalunan filed a motion for leave to intervene, alleging that Celso was the bona fide agricultural tenant of a portion of the land. They sought payment of just compensation for his landholding or, alternatively, disturbance compensation as a tenant. The trial court, through respondent Judge Roque A. Tamayo, denied the motion, ruling that admitting the intervention would allow a suit against the State without its consent, as the claim for disturbance compensation was effectively a claim against the State.
Meanwhile, the Republic appealed the trial court’s decision fixing compensation. The trial court dismissed the Republic’s appeal as filed out of time, a ruling eventually overturned by the Supreme Court in a separate petition (G.R. No. 54886), which directed the trial court to approve and elevate the record on appeal.

ISSUE

The principal issue is whether the trial court correctly denied the petitioners’ motion to intervene in the expropriation proceedings.

RULING

The Supreme Court denied the petition, upholding the trial court’s denial of intervention. Intervention is not a matter of right but requires a showing of a legal interest in the matter in litigation—an interest that is actual, direct, and material, not contingent or expectant. Petitioners based their claim on a Certificate of Land Transfer (CLT) issued under Presidential Decree No. 27, arguing the phrase “deemed owner” entitled Celso Pagtalunan to just compensation from the expropriation proceeds. The Court rejected this, clarifying that a CLT grantee is not the legal owner of the land but merely has a provisional right to possess and cultivate it, with full ownership vesting only upon full payment of amortizations. Since legal title remained with the registered owners (the Aldabas), the just compensation payable by the State belonged to them, not the tenant-petitioners.
The Court also found petitioners not entitled to disturbance compensation under Republic Act No. 3844, as amended. Such compensation is due when the landowner/lessor voluntarily converts the land to non-agricultural use. Here, the conversion was compelled by the State’s expropriation for a public purpose, independent of the landowners’ will. The government had already compensated Celso Pagtalunan for improvements and relocation expenses. On the ancillary issue of jurisdiction, the Court noted that Batas Pambansa Blg. 129 had vested exclusive original jurisdiction over such matters in the Regional Trial Courts (formerly Courts of First Instance), rendering the jurisdictional challenge moot.