GR 172852; (January, 2013) (Digest)
G.R. No. 172852 ; January 30, 2013
CITY OF CEBU, Petitioner, vs. APOLONIO M. DEDAMO, JR., Respondent.
FACTS
The City of Cebu filed an eminent domain case against spouses Apolonio and Blasa Dedamo. The parties entered into a compromise agreement for provisional payment, and a panel of commissioners later recommended just compensation of ₱20,826,339.50, which the RTC approved. This valuation was affirmed with finality by the Supreme Court in a prior decision ( G.R. No. 142971 ) on May 7, 2002. The City paid the unpaid balance of the compensation on December 23, 2003.
Respondent Apolonio Dedamo, Jr., as substitute for his deceased parents, moved for the payment of legal interest on the just compensation. The RTC denied the motion, ruling it could not amend a final judgment that did not order interest. On appeal, the Court of Appeals partially granted Dedamo’s motion. It rejected the claim for interest from the date of taking as belated but awarded 12% legal interest per annum from the finality of the Supreme Court’s decision (May 7, 2002) until full payment was made on December 23, 2003.
ISSUE
Whether the Court of Appeals erred in awarding 12% legal interest on the just compensation from the date of finality of the judgment.
RULING
The Supreme Court denied the City’s petition on the ground of res judicata, specifically conclusiveness of judgment. The core issue of the respondent’s entitlement to 12% legal interest had already been conclusively settled in a related case, G.R. No. 172942, which was filed by respondent Dedamo. In that case, Dedamo sought to have the interest reckoned from the date of taking, but the Supreme Court denied his petition, thereby upholding the CA’s decision to compute interest from the date of finality. This prior ruling constitutes a final adjudication on the matter of whether and from when legal interest is due.
The principle of conclusiveness of judgment bars the re-litigation of facts and issues already determined in a former case between the same parties, even if the causes of action differ. Since the petitioner City of Cebu was the opposing party in G.R. No. 172942, it is bound by the Court’s prior determination that the CA correctly awarded 12% interest from the date of finality. The City cannot now, through a separate petition, challenge an award that is inextricably linked to and upheld in the earlier resolved case. The petition was therefore denied.