G.R. No. 214310 , February 24, 2020
Republic of the Philippines represented by the Department of Public Works and Highways (DPWH), Petitioner, vs. Estate of Juan Maria Posadas III, Maria Elena Posadas, and Estela Marfori de Posadas, Respondents.

FACTS

On July 4, 1990, the Republic, through the DPWH, filed a complaint for expropriation before the RTC of Makati against owners of land along Sucat Road in Parañaque for a road-widening project. The respondents opposed the complaint. The Republic alleged the property’s appraised value was P18,664,800.00, which the Estate of Juan Maria Posadas III contested as too low. On January 8, 1991, the Republic deposited 10% of this value (P1,866,480.00) and filed for a writ of possession. The respondents did not contest the public purpose and, on July 16, 1993, filed a joint motion to withdraw the deposit while reserving their right to claim higher compensation. The RTC allowed the withdrawal on July 26, 1993. On August 6, 1993, the respondents filed another motion to withdraw the balance of the provisional value (P16,798,320.00), but the Republic never paid this balance.
On November 3, 1998, DPWH Secretary Gregorio Vigilar informed the OSG that the government would no longer pursue the expropriation case due to the Skyway Project. On July 11, 2005, the Estate filed a manifestation with motion praying for dismissal, arguing abandonment, and sought to present evidence on damages. However, on March 27, 2005, Acting DPWH Secretary Hermogenes Ebdane, Jr. wrote that the Republic had changed its position and decided to pursue the expropriation and acquire more land. The Republic thus opposed the motion to dismiss.
On July 1, 2007, the Estate filed a motion for payment of just compensation and for inclusion of all affected property, noting a road had already been constructed and the plan was altered, affecting other respondent properties. The DPWH confirmed it would occupy a different portion. On March 11, 2008, the RTC ordered the Republic to submit an amended complaint to reflect the new area. The Republic failed to comply. On March 26, 2008, the RTC again directed the Republic to file an amended complaint within 30 days. Instead, the Republic filed a manifestation noting the death of respondent Maria Elena Posadas and prayed for suspension to await her substitute. On May 23, 2008, the RTC gave the Republic until August 20, 2008, to amend the complaint. The Republic sought extensions on August 27, 2008, and again on September 26, 2008, citing difficulty in securing funds. The RTC granted extensions but stated the last one would not be subject to further extension. The Republic still did not file the amended complaint.
The OSG failed to appear at a scheduled hearing. On May 12, 2009, the RTC ordered the OSG to explain why it should not be cited for contempt for repeated non-appearance and failure to file the amended complaint. The OSG responded that the assigned state solicitor had prolonged travel time due to Skyway construction. On December 7, 2009, the respondents orally moved for dismissal for failure to comply with the court order. The RTC granted the motion and dismissed the case under Rule 17, Section 3 of the Rules of Court. The Republic’s motion for reconsideration was denied. The CA affirmed the RTC’s dismissal.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of the expropriation case for the Republic’s failure to comply with the trial court’s order to amend the complaint.

RULING

No, the Court of Appeals did not err. The Supreme Court denied the petition and affirmed the CA decision. The Court held that the State’s power of eminent domain must be exercised within the bounds of the constitutional guarantee of just compensation, which includes not only payment of the property’s fair market value but also payment within a reasonable time. The Republic’s protracted delay and vacillation—initially abandoning the project in 1998, then reviving it in 2005, failing to pay the balance of the provisional compensation, and repeatedly failing to comply with court orders to amend its complaint over more than a year—constituted an inequitable disregard of the respondents’ proprietary rights. The dismissal was a proper sanction for the Republic’s failure to prosecute its action and comply with court orders. The Court emphasized that the government is not exempt from the rules of procedure and must observe the same standard of conduct required of private parties. The delays amounted to a denial of the respondents’ right to just compensation, warranting dismissal of the expropriation complaint.