GR 214782; (April, 2019) (Digest)
G.R. No. 214782 , April 3, 2019
NATIONAL TRANSMISSION CORPORATION, Petitioner, vs. BERMUDA DEVELOPMENT CORPORATION, Respondent.
FACTS
Respondent Bermuda Development Corporation (BDC) filed an unlawful detainer case against petitioner National Transmission Corporation (TransCo) before the Municipal Trial Court (MTC) of Cabuyao, Laguna, concerning a parcel of land. The MTC ruled in favor of BDC, ordering TransCo to vacate the property and pay monthly rentals. TransCo appealed to the Regional Trial Court (RTC), Branch 24. While the appeal was pending, BDC secured a writ of execution pending appeal, leading to a garnishment of TransCo’s bank account. TransCo subsequently filed a separate complaint for expropriation of the same property before RTC, Branch 25, and deposited a provisional value. Branch 25 granted TransCo’s motion and issued a writ of possession.
RTC Branch 24, where the detainer appeal was lodged, then dismissed TransCo’s appeal as moot and academic, citing the filing of the expropriation case and the fact that possession had already been delivered to TransCo via the writ of possession from Branch 25. The RTC also ordered the remand of the case to the MTC for enforcement of the judgment on rental arrears. The Court of Appeals affirmed this dismissal, reasoning that requiring TransCo to vacate only to be restored to possession via expropriation would cause circuitous delays in government projects. It held that the rental arrears awarded by the MTC should be enforced separately from the just compensation in the expropriation case.
ISSUE
Whether the MTC had jurisdiction over the unlawful detainer case filed by BDC against TransCo, a public utility corporation with the power of eminent domain, for its occupation of the property for public use.
RULING
The Supreme Court granted the petition and dismissed the unlawful detainer complaint. The Court held that the MTC lacked jurisdiction over the case. Citing jurisprudence, notably National Power Corporation v. Codilla, Jr., the Court reiterated the settled rule that an action for unlawful detainer or ejectment is not an available remedy against a government entity or public utility endowed with the power of eminent domain which occupies private property for public use, even if the entry was made without prior expropriation proceedings or negotiated purchase. The property owner’s recourse in such a scenario is to file an action for the proper recovery of possession, which is not an ejectment case, or to await the filing of expropriation proceedings. The MTC, therefore, had no authority to entertain the complaint, order TransCo to vacate, and award rental arrears.
Consequently, the MTC Decision, the RTC Orders dismissing the appeal as moot, and the CA Decision affirming them were all reversed and set aside. The filing of the expropriation case did not render the detainer case moot; rather, the detainer case was void from inception for lack of jurisdiction. The proper forum for determining BDC’s compensation, including any claims for damages for the temporary occupancy, is the expropriation case pending before RTC Branch 25, where just compensation and consequential damages are to be adjudicated pursuant to Rule 67 of the Rules of Court.