G.R. No. 146587; July 2, 2002
Republic of the Philippines, represented by the General Manager of the Philippine Information Agency (PIA), petitioner, vs. The Honorable Court of Appeals and the Heirs of Luis Santos, respondents.

FACTS

The Republic, through the Philippine Information Agency, initiated expropriation proceedings in 1969 over several parcels of land in Bulacan, including a 76,589-square meter property owned by Luis Santos, for a radio broadcast facility. The trial court rendered a judgment of condemnation in 1979, fixing just compensation at P6.00 per square meter. Despite this final order, the government failed to pay the Santos heirs.
In 1984, the heirs secured a writ of execution, but it was not enforced. The property was subsequently subdivided by presidential proclamation in 1999, with portions transferred to the Bulacan State University. In September 1999, over twenty years after the judgment, the government moved to deposit compensation at the 1979 rate. The heirs opposed, seeking an adjustment to the current zonal value of P5,000.00 per square meter or, alternatively, the return of their property.

ISSUE

The primary issue is whether the government’s failure to pay just compensation for an extended period warrants the return of the expropriated property to the owners.

RULING

The Supreme Court ruled in favor of the heirs and ordered the return of the property. The legal logic is anchored on the fundamental nature of expropriation as an involuntary taking conditioned upon immediate payment of just compensation. The Court emphasized that the government’s failure to pay within a reasonable time constitutes a violation of a constitutional and statutory condition, rendering the taking fundamentally flawed.
The 1979 judgment became final and executory, but the right to execute it by motion prescribed after five years. While an independent action to enforce the judgment remained possible, the extraordinary delay of over two decades—during which the government even alienated portions of the land—was deemed unreasonable and tantamount to a denial of substantive due process. Citing precedent, the Court held that where the government fails to pay just compensation, the owners retain a “right to revert” to the property. The State’s act of transferring the property to another entity before paying the original owners further aggravated the violation. Thus, the appropriate remedy is restitution, as the expropriation was not completed by payment, leaving the heirs’ ownership interest effectively undisturbed. The government’s belated tender of payment at the 1979 valuation, long after the property’s value had escalated, was insufficient to cure this defect.