G.R. No. 173392 ; August 24, 2007
PHILIPPINE PORTS AUTHORITY, Petitioner, vs. REMEDIOS ROSALES-BONDOC, ET AL., Respondents.

FACTS

The Philippine Ports Authority (PPA) filed a complaint for expropriation of 185 lots in Batangas City for the development of Phase II of the Batangas Port Zone. The trial court issued a writ of possession, and PPA took possession of the properties on September 11, 2001, after depositing an amount based on an initial valuation. Court-appointed commissioners submitted a Partial Report recommending a just compensation of ₱4,800.00 per square meter. The trial court, however, issued separate orders fixing the compensation at ₱5,500.00 per square meter for the various groups of respondents.
PPA filed petitions for certiorari with the Court of Appeals, challenging the trial court’s orders. The appellate court dismissed the petitions, ruling that the orders were interlocutory and thus not subject to certiorari, and that PPA’s remedy was an ordinary appeal after the rendition of a final judgment determining just compensation. PPA elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in dismissing PPA’s petitions for certiorari and in ruling that the trial court’s orders fixing just compensation were merely interlocutory.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The trial court’s orders fixing just compensation at ₱5,500.00 per square meter were deemed final and executory as to the specific groups of respondents for whom they were issued. The legal logic is grounded in the nature of expropriation proceedings under Rule 67 of the Rules of Court. An order of condemnation or an order fixing the amount of just compensation is a final order if it finally disposes of the case against a particular party, leaving nothing more to be done by the court regarding their claim. Here, the separate orders for the different respondent groups, having determined the compensation definitively, were final as to those parties.
Consequently, PPA’s remedy was a timely ordinary appeal, not a special civil action for certiorari, which is reserved for correcting errors of jurisdiction, not errors of judgment. Since PPA failed to perfect an appeal, the orders became final and executory. The Supreme Court directed the trial court to implement these final orders, including the payment of 12% interest per annum from the date of taking, September 11, 2001, until full payment, with the initial deposit to be deducted.