Republic of the Philippines vs. Heirs of Lacsina, Cabever Realty Corporation, St. Ignatius of Loyola School

Case Title and Citation

Republic of the Philippines, represented by the Department of Public Works and Highways - National Capital Region (DPWH-NCR), petitioner, vs. Heirs of Isabel D. Lacsina, represented by Higino Honorato D. Lacsina and Reynaldo D. Lacsina, deceased and survived by Ma. Evelyn R. Lacsina, Marina M. Rimas, Rei Mari Lacsina, Marie Claire Lacsina, and Rei Francis Lacsina; Cabever Realty Corporation; and St. Ignatius of Loyola School, respondents.
G.R. No. 246356, October 11, 2021
Supreme Court - Second Division
Ponente: Justice Inting

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Facts

• On May 12, 2009, the Republic (DPWH-NCR) filed a Complaint for expropriation of three parcels in Ususan, Taguig City for completion of the Taguig Diversion Road:
  1. Lot 5301-A — Owner: Heirs of Isabel D. Lacsina; Area: 788 sq. m.; Classification: Agricultural; BIR zonal valuation: ₱2,000.00/sq. m.
     2. Lot 5897-E — Owner: Cabever Realty Corporation; Area alleged in complaint: 1,355 sq. m.; Classification: Commercial; BIR zonal valuation: ₱6,000.00/sq. m.
     3. Lot 5897-B — Owner: St. Ignatius of Loyola School (SILS); Area: 1,654 sq. m.; Classification: Residential; BIR zonal valuation: ₱5,000.00/sq. m.
• RTC issued an Order of Expropriation on June 1, 2011. Respondents did not contest the Republic’s right to expropriate but objected to provisional valuations and contended their properties’ market values were higher.
• Respondent contentions included:
  • Heirs of Lacsina: market value not less than ₱6,000.00/sq. m.; disputed date of taking.
  • Cabever: claimed higher fair market value (₱19,000–20,000/sq. m.), sought consequential damages because expropriation would split and render remaining portions irregular and hard to dispose.
  • SILS: claimed location along Gen. Luna St. (or Levi Mariano Ave.), cited higher zonal valuation (up to ₱60,000.00/sq. m. per BIR revision), sought just compensation of ₱25,000–30,000/sq. m. and consequential damages for loss of intended campus expansion.
• The parties created a board of commissioners under Rule 67. The commissioners’ Report dated July 10, 2012 recommended:
  1. Fair market value at ₱10,000.00/sq. m. for the subject properties;
  2. Consequential damages to Cabever’s unaffected lots at ₱5,000.00/sq. m.; and
  3. Consequential damages to SILS’ unaffected property at ₱5,000.00/sq. m.
• The RTC directed resurvey and received subdivision plans and survey reports. Disputes included an alleged 112 sq. m. discrepancy in Cabever’s land and differing zonal valuations for SILS after a 2012 BIR revision.
• RTC Decision dated February 18, 2015:
  • Found properties used for commercial purposes and fixed just compensation at ₱15,000.00/sq. m. for all three properties.
  • Denied consequential damages to Cabever and SILS.
  • Ordered payment amounts based on ₱15,000.00/sq. m.
• Republic’s Motion for Reconsideration was denied on September 4, 2015. The Republic appealed to the Court of Appeals.
• CA Decision dated October 18, 2018:
  • Computed just compensation at ₱10,000.00/sq. m. for the expropriated properties.
  • Awarded consequential damages of ₱5,000.00/sq. m. for the unaffected portions of Cabever and SILS.
  • Imposed legal interest: 12% per annum from May 12, 2009 until June 30, 2013; 6% per annum from July 1, 2013 until fully paid.
• CA denied the Republic’s Motion for Partial Reconsideration by Resolution dated March 21, 2019.
• The Republic filed a petition for review on certiorari in the Supreme Court raising primarily the issues of the CA’s authority to award consequential damages and whether Cabever and SILS were entitled to consequential damages.

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Issues

1. Did the Court of Appeals exceed its jurisdiction when it awarded consequential damages to Cabever and SILS despite those parties not appealing the RTC decision denying consequential damages?
2. Assuming the Court of Appeals could pass upon the issue, are Cabever Realty Corporation and St. Ignatius of Loyola School entitled to consequential damages for the unaffected portions of their respective properties?

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Ruling

1. Yes - The Court of Appeals exceeded its jurisdiction in awarding consequential damages to Cabever and SILS because those appellees did not appeal the RTC decision denying consequential damages and an appellee who has not appealed cannot obtain affirmative relief beyond the lower court’s decision.
2. No - Cabever and SILS are not entitled to consequential damages in this case insofar as the award stems from relief they did not seek by appeal; the Court deleted the CA’s award of consequential damages.

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Reasoning / Ratio Decidendi

• Finality and appellation limits:
  • A decision becomes final as to a party who does not appeal it; an appellee who has not appealed cannot obtain from the appellate court any affirmative relief other than those granted in the decision of the court below. The Court relied on prior decisions including Hiponia-Mayuga v. Metropolitan Bank and Trust Co., Javines v. Xlibris, and PNB v. Spouses Rabat to reiterate this rule.
• Scope of Section 8, Rule 51:
  • Section 8, Rule 51 of the Rules of Court allows appellate consideration of errors not assigned only if closely related to assigned errors or for plain or clerical errors, but the Court emphasized that the exceptions are for the benefit of the appellant and not for the appellee.
  • Here the Republic (appellant before the CA) raised only the proper determination of just compensation; Cabever and SILS (appellees) did not appeal the RTC denial of consequential damages and in their appellate briefs agreed with the RTC decision.
• Application to the case:
  • Because Cabever and SILS did not perfect an appeal seeking consequential damages, the issue had become final and executory as to them; the CA erred in applying Section 8, Rule 51 to grant them affirmative relief.
  • The Supreme Court therefore deleted the CA’s award of consequential damages without reaching or adjudicating the evidentiary sufficiency of respondents’ claims for such damages.

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Doctrine / Legal Principle

• A judgment is final as to a party who does not perfect an appeal; appellate courts lack jurisdiction to grant affirmative relief to a non-appealing appellee beyond the lower court’s disposition.
• Section 8, Rule 51 exceptions (unassigned errors) are available primarily for the benefit of the appellant and cannot be used to expand relief in favor of an appellee who did not appeal.
• Appellate courts must respect the limits of issues properly raised on appeal; affirmative relief must be sought by the party who would benefit.

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Disposition

• Petition is GRANTED.
• The Decision dated October 18, 2018 and the Resolution dated March 21, 2019 of the Court of Appeals in CA-G.R. CV No. 106325 are AFFIRMED with MODIFICATION: the award of consequential damages in favor of Cabever Realty Corporation and St. Ignatius of Loyola School in the amount of ₱5,000.00 per square meter for the unaffected portions of their respective properties is DELETED.
• The remainder of the CA decision, as affirmed by the Supreme Court (including computation of just compensation and legal interest as previously determined by the CA), stands as modified.

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Concurring / Dissenting Opinions

• Justices Hernando (Acting Chairperson), Gaerlan, and Dimaampao concurred.
• Chief Justice Perlas-Bernabe was on official leave.

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Significance / Notes

• Practical effect: Appellees who do not appeal cannot obtain additional affirmative relief from an appellate court; parties seeking further recovery must timely perfect an appeal.
• The Court refrained from evaluating the factual sufficiency of evidence supporting consequential damages because the award was procedurally barred.
• The decision underscores the limited application of Section 8, Rule 51 exceptions and reinforces finality of judgments as to non-appealing parties.
• The Court dispensed with the comment of Ma. Evelyn for failure to file.