G.R. No. L-8429; March 7, 1914
THE CITY OF MANILA, plaintiff-appellee, vs. EVARISTO BATLLE, ET AL., defendants-appellants.

FACTS:
The City of Manila filed a complaint to condemn certain lots, including those belonging to defendants Evaristo Batlle and his wife, for the purpose of widening a public street. The defendants admitted the city’s right to condemn and claimed damages of P196,000. A condemnation commission was appointed, which, after proceedings, awarded the defendants a total of P119,173.40 for the land and improvements. Upon the filing of the commission’s report, the City Attorney moved for the court to confirm it. Counsel for both parties jointly and verbally requested the court in open court to confirm the report. However, the trial court, disregarding this agreement and without further notice or evidence, rendered a judgment disapproving the report as to the Batlles, reducing their award to P150,144.50. The defendants moved for a new trial, which was denied, prompting their appeal.

ISSUE:
Whether the trial court acted within its authority when it disregarded the parties’ agreement to confirm the commissioners’ report and, on its own motion, rendered a judgment altering the award.

RULING:
No. The Supreme Court reversed the trial court’s judgment. Under Section 246 of the Code of Civil Procedure, the court’s primary duty upon the filing of the commissioners’ report is to accept it and render judgment accordingly. The court may only recommit the report, set it aside, or accept it in part and reject it in part “for cause shown.” The showing of cause is a condition precedent for any action other than confirmation, and such cause must be shown by the interested parties. In this case, both parties had affirmatively agreed to and jointly requested the confirmation of the report. In the absence of any showing of causesuch as fraud, corruption, or bad faiththe trial court had no authority to disregard the agreement and unilaterally alter the award. The case was remanded with instructions to enter judgment confirming the award made by the commissioners.