G.R. No. 198139, September 8, 2014
NATIONAL POWER CORPORATION, Petitioner, vs. FELICISIMO TARCELO and HEIRS OF COMIA SANTOS, Respondents.

FACTS

Petitioner National Power Corporation (NPC) filed an expropriation case (Civil Case No. 5785) to acquire an easement of right-of-way over portions, totaling 1,595.91 square meters, of respondents’ two agricultural lots (with total areas of 4,404 and 2,611 square meters) in Batangas City for its natural gas pipeline project. The Regional Trial Court (RTC) fixed just compensation at ₱1,000.00 per square meter. NPC appealed (CA-G.R. CV No. 86712), and the Court of Appeals (CA) modified the decision, lowering the just compensation to ₱797.50 per square meter. This CA decision became final and executory. When respondents moved for execution, the RTC issued a Writ of Execution and a Notice of Garnishment for ₱5,594,462.50, which represented payment for the entire area of respondents’ lots (7,015 sq m), not just the 1,595.91 sq m portion originally sought. NPC filed an Urgent Omnibus Motion to quash the writ, arguing it should pay only for the affected area. The RTC denied the motion, ruling that the imposition of the underground pipeline rendered the entire property useless for agricultural purposes, akin to a taking of the whole. NPC filed a Petition for Certiorari with the CA (CA-G.R. SP No. 112054), which was denied. The CA held that the RTC’s order was in accord with the final and executory CA decision in the expropriation appeal, which it interpreted as having awarded compensation for the entire property. NPC’s motion for reconsideration was also denied.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s order granting execution for the payment of just compensation covering the entire area of respondents’ lots, instead of being limited to the portion actually traversed by the pipeline.

RULING

Yes, the Court of Appeals erred. The Supreme Court granted NPC’s petition and reversed the CA’s rulings. The Court held that the dispositive portion of the final and executory CA Decision in CA-G.R. CV No. 86712 only modified the rate of just compensation from ₱1,000.00 to ₱797.50 per square meter. It did not alter the subject of the expropriation, which, as clearly stated in the RTC Decision, was only the “portions of the properties” totaling 1,595.91 square meters. The body of the CA decision discussed the entitlement to full market value (as opposed to a mere 10% easement fee) for the affected area, but it did not decree payment for the entire lot. Execution must conform strictly to the dispositive portion of a final judgment. The RTC and the CA in the certiorari proceedings therefore committed grave abuse of discretion by ordering execution beyond the scope of the final judgment, which awarded compensation only for the area affected by the pipeline easement. The Supreme Court made the injunction permanent and ordered the RTC to issue a new writ of execution strictly conforming to the final CA decision.