G.R. No. 226138. March 23, 2022.
REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE DEPARTMENT OF PUBLIC WORKS AND HIGHWAYS, PETITIONER, VS. ESPINA & MADARANG, CO. AND MAKAR AGRICULTURAL CORP., RESPONDENTS.

FACTS

The case involves a dispute over compensation for the road right of way (RROW) taken by the government for the construction of the Cotabato-Kiamba-General Santos-Koronadal National Highway. The heirs of Olarte Hermanos y Cia Estate initially claimed compensation based on Original Certificate of Title No. 12 (OCT No. 12). The Regional Trial Court (RTC) of Cotabato City, in Special Proceedings No. 2004-074, ordered the Department of Public Works and Highways (DPWH) to pay the heirs. However, respondents Espina & Madarang, Co. and Makar Agricultural Corp. (Espina and Makar) filed a complaint for injunction (Civil Case No. 7788) before the RTC of General Santos City, asserting ownership over the property. They traced their title from a mortgage foreclosure sale to El Hogar Filipino in 1933, subsequent sales to the Espina sisters, and eventually to Makar and Espina. They sought to enjoin DPWH from paying the Olarte heirs. The RTC of General Santos City, noting that a Court of Appeals (CA) Decision in a related case (CA-G.R. SP No. 02302-MIN) had affirmed that the Olarte heirs were no longer owners, declared the injunction case moot and academic. It then ordered the DPWH to deliver the RROW compensation to Espina and Makar and issued garnishment orders against DPWH funds. The Republic, through DPWH, challenged these orders via a petition for certiorari (CA-G.R. SP No. 03310-MIN), but the CA denied it. The Supreme Court, in G.R. No. 202416, denied the Republic’s subsequent petition. After this denial became final, Espina and Makar moved for execution. The RTC of General Santos City, in an Order dated December 16, 2013, directed the sheriff to implement the writ of execution. The Republic filed a Motion for Reconsideration and to Quash the Writ of Execution, which the RTC denied in Orders dated February 24, 2014 and July 21, 2014. The CA, in CA-G.R. SP No. 06472-MIN, affirmed these RTC Orders. The Republic then filed the present Petition for Review on Certiorari.

ISSUE

The core issue is whether the RTC of General Santos City acted with grave abuse of discretion in issuing the Orders dated December 16, 2013, February 24, 2014, and July 21, 2014, which directed the execution of its earlier orders for the payment of RROW compensation to Espina and Makar and authorized garnishment of DPWH funds.

RULING

The Supreme Court DENIED the petition and AFFIRMED the assailed CA Decision and Resolution. The Court held that the RTC did not commit grave abuse of discretion. The ownership of Espina and Makar over the subject property had been definitively settled by the final and executory Decision in G.R. No. 202416, which upheld the CA ruling that the Olarte heirs were no longer the owners. The principle of conclusiveness of judgment barred the relitigation of this issue. The Court also ruled that the grant of compensation in the injunction case was proper, as the prayer for relief included a request for “other reliefs just and equitable,” which encompassed the payment due to the established owners. Furthermore, the garnishment of public funds was permissible in this instance because the money judgment was based on the government’s liability for the taking of private property for public use (expropriation), and the funds in question had already been allocated and appropriated for the specific purpose of paying the RROW compensation. The Court emphasized that the doctrine of non-suability of the state and the immunity of public funds from garnishment are not absolute and do not apply when the funds are already earmarked for a valid debt of the government.