GR 93868; (February, 1991) (Digest)
March 16, 2026AM RTJ 99 1448; (April, 2000) (Digest)
March 16, 2026G.R. No. 146886; April 30, 2003
DEVORAH E. BARDILLON, petitioner, vs. BARANGAY MASILI OF CALAMBA, LAGUNA, respondent.
FACTS
Respondent Barangay Masili filed an expropriation complaint before the Municipal Trial Court (MTC) to acquire petitioner Devorah Bardillon’s 144-square-meter lot for a multi-purpose hall. The MTC dismissed this first case (Civil Case No. 3648) for failure of the barangay and its counsel to appear at pre-trial. Subsequently, the barangay filed a second expropriation complaint for the same property before the Regional Trial Court (RTC). Petitioner moved to dismiss this second case, arguing it was barred by res judicata due to the prior dismissal by the MTC.
The RTC denied the motion to dismiss, holding that the MTC lacked jurisdiction over the expropriation proceeding from the outset. The RTC later issued orders in favor of the barangay, including a writ of possession. The Court of Appeals affirmed the RTC’s actions, prompting this petition.
ISSUE
The primary issue is whether the MTC had jurisdiction over the first expropriation case, such that its dismissal would bar the second filing under the principle of res judicata.
RULING
The Supreme Court denied the petition, affirming the rulings of the lower courts. The Court held that an action for expropriation is incapable of pecuniary estimation. The essence of such a suit is the government’s exercise of its sovereign authority to take private property for public use upon payment of just compensation. It is not an action for the recovery of a sum of money, the value of which would determine jurisdiction.
Consequently, jurisdiction over expropriation cases is vested exclusively in the Regional Trial Courts under Section 19(1) of Batas Pambansa Blg. 129, as amended, regardless of the assessed or market value of the property involved. Since the MTC had no jurisdiction over the first expropriation case (Civil Case No. 3648), its dismissal order was void and produced no legal effect. A void judgment cannot constitute res judicata. Therefore, the barangay’s refiling of the complaint before the RTC, the court with proper jurisdiction, was valid and not barred. The Court found no merit in petitioner’s ancillary issues regarding forum shopping and the propriety of the writ of possession.
