GR 87335; (February, 1990) (Digest)
G.R. No. 87335 February 12, 1990
REPUBLIC OF THE PHILIPPINES, petitioner, vs. CRISTINA DE KNECHT AND THE COURT OF APPEALS, respondents.
FACTS
The Republic initiated expropriation proceedings in 1979 for properties along Fernando Rein-Del Pan streets to extend EDSA for flood control and traffic relief. Respondent Cristina de Knecht challenged this, and in G.R. No. L-51078 (1980), the Supreme Court granted her petition, ruling the choice of route was arbitrary and permanently enjoining further action in the expropriation case except its dismissal. The decision became final. Subsequently, in 1983, Batas Pambansa Blg. 340 was enacted, expressly expropriating the same properties for the identical public purpose. The Republic then moved to dismiss the original case based on this new law. The trial court granted the dismissal, but the Court of Appeals reversed, reinstating the Supreme Court’s 1980 final judgment as the law of the case and dismissing the expropriation on the ground of arbitrariness.
ISSUE
Whether a final judicial judgment dismissing an expropriation proceeding bars a subsequent legislative enactment expropriating the same properties for the same public purpose.
RULING
No. The Supreme Court granted the Republic’s petition and reinstated the trial court’s order dismissing the case based on B.P. Blg. 340. The Court held that the legislative enactment effectively superseded the prior final judgment. The 1980 decision was based on the executive department’s arbitrary choice of route. However, B.P. Blg. 340 represents an independent, sovereign legislative determination and flat expropriating the property. The legislature has the inherent power to make its own assessment of public necessity and, through a specific law, directly authorize the taking. This subsequent legislative act constitutes a supervening event that alters the legal landscape. The Court clarified that it was not allowing a legislative reversal of a judicial finding but recognizing that the law was enacted under changed circumstances justifying the expropriation. Therefore, the final judicial decision must yield to the subsequent valid exercise of legislative power. The enactment of B.P. Blg. 340 provided a proper and new legal basis for the expropriation, rendering the prior dismissal moot.