TL;DR

In a Philippine expropriation case, the Supreme Court clarified that appellate courts cannot grant affirmative relief to appellees on issues they did not appeal. The Court overturned a Court of Appeals (CA) decision that awarded consequential damages to property owners (Cabever Realty and St. Ignatius School) when these owners had not appealed the Regional Trial Court’s (RTC) denial of such damages. The Supreme Court emphasized that failing to appeal a lower court’s decision renders it final and unalterable against the non-appealing party. This ruling reinforces the principle that appellate review is limited to errors raised by appellants, ensuring fairness and procedural order in expropriation and other legal disputes. Property owners must actively appeal unfavorable rulings to seek further remedies at the appellate level.

When Silence Isn’t Golden: Appealing for Consequential Damages in Expropriation

This case, Republic of the Philippines v. Heirs of Isabel D. Lacsina, revolves around the crucial legal principle of appellate procedure in the context of expropriation. The Republic, through the Department of Public Works and Highways (DPWH), initiated expropriation proceedings to acquire land for the Taguig Diversion Road project. While the Regional Trial Court (RTC) determined just compensation for the taken properties, it denied consequential damages to Cabever Realty Corporation (Cabever) and St. Ignatius of Loyola School (SILS) for the reduced value of their remaining land. Crucially, only the Republic appealed the RTC decision, contesting the amount of just compensation. Cabever and SILS, satisfied with the just compensation awarded, did not appeal the RTC’s denial of consequential damages.

The Court of Appeals (CA), however, modified the RTC decision, not only reducing the just compensation but also surprisingly awarding consequential damages to Cabever and SILS. The Republic questioned this award before the Supreme Court, arguing that the CA exceeded its jurisdiction by granting relief on an issue not raised on appeal by Cabever and SILS. The central legal question became: can an appellate court grant affirmative relief to appellees on issues they did not appeal, especially when only the opposing party appealed the lower court’s decision?

The Supreme Court anchored its decision on the well-established principle of appellate procedure that a party who does not appeal a decision is bound by it. The Court cited Hiponia-Mayuga v. Metropolitan Bank and Trust Co., et al., reiterating that “an appellee who has not himself appealed cannot obtain from the appellate court any affirmative relief other than those granted in the decision of the court below.” This principle is rooted in the concept of finality of judgments. Once the period to appeal lapses without a party filing an appeal, the lower court’s decision becomes final and immutable against that party.

The Rules of Court, specifically Section 8, Rule 51, further limits the scope of appellate review. This rule states that appellate courts will only consider errors that affect jurisdiction or the validity of the judgment, or those stated in the assignment of errors by the appellant. While exceptions exist for errors closely related to assigned errors or plain errors, the Supreme Court emphasized, citing PNB v. Spouses Rabat, that these exceptions are “for the benefit of the appellant and not for the appellee.”

In this case, Cabever and SILS did not appeal the RTC’s denial of consequential damages. Their appellee briefs before the CA sought affirmation of the RTC decision, except for the interest rate. Therefore, the issue of consequential damages, as far as Cabever and SILS were concerned, had become final. The Republic’s appeal focused solely on the amount of just compensation. The CA, in awarding consequential damages, effectively granted affirmative relief to appellees who did not appeal, violating established procedural rules.

The Supreme Court clarified that the issue of consequential damages is distinct from just compensation for the expropriated properties. Even if related, the exceptions under Rule 51, Section 8, could not be used to benefit non-appealing appellees. The CA’s action was deemed an erroneous application of these exceptions. Consequently, the Supreme Court reversed the CA’s award of consequential damages, reinstating the RTC’s decision on this specific point.

This ruling underscores the importance of timely and proper appeals. Parties dissatisfied with a lower court’s decision, even partially, must actively appeal to seek appellate review and potential relief. Silence and inaction, by failing to appeal, signify acceptance of the unfavorable portions of the judgment. The Republic v. Lacsina case serves as a clear reminder of the procedural boundaries of appellate courts and the necessity for parties to diligently pursue their legal remedies through appeal to secure their desired outcomes.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Republic of the Philippines vs. Heirs of Isabel D. Lacsina, G.R. No. 246356, October 11, 2021