FACTS:

Petitioner filed expropriation proceedings before the RTC of Bulacan to acquire land for the "Voice of the Philippines" project. After more than nine years, the trial court issued a judgment condemning the properties and ordered the petitioner to pay just compensation. However, the government failed to pay the compensation to the heirs of the previous owner of a portion of the expropriated land. Respondents filed a motion seeking payment, which was granted by the trial court. Despite this, respondents remained unpaid, and petitioner filed a motion to deposit just compensation, but respondents opposed this and filed a counter-motion to have the expropriated property returned to them. The trial court ruled in favor of the respondents and ordered the return of the property. Petitioner's petition to the Court of Appeals was denied based on procedural grounds. The petitioner argues that the respondents' motions interrupted the prescriptive period to enforce the judgment. The petitioner also contends that the respondents' receipt of partial compensation in 1984 estopped them from invoking prescription. The Court decides to resolve the case on its merits.

ISSUES:

1. Whether the motion filed by respondents interrupted the 5-year prescriptive period to enforce the 1979 judgment.

2. Whether the partial payment made by petitioner estopped respondents from invoking prescription.

3. Whether the transfer of ownership to Bulacan State University was valid even without final settlement of just compensation.

4. Whether the local government has the power of eminent domain.

5. Whether the landowners are entitled to recover possession of their expropriated lots or only to demand the fair market value.

6. Whether or not the Regional Trial Court (RTC) acted beyond its lawful cognizance by ordering the payment of just compensation for the expropriated property.

7. Whether or not the private respondents are entitled to the return of the expropriated property.

RULING:

1. The motion filed by respondents did not interrupt the 5-year prescriptive period. According to Section 6, Rule 39 of the Rules of Court, a motion to enforce the judgment must be made by the prevailing party, in this case, petitioner.

2. The partial payment made by petitioner did not estop respondents from invoking prescription. The payment made was part of the initial deposit made by petitioner in 1969 and cannot be considered as partial payment of just compensation.

3. The transfer of ownership to Bulacan State University was valid even without final settlement of just compensation. Once property is expropriated and assumed public character, the condemnor has the right to decide the use of the property for public purposes.

4. The power of eminent domain cannot be understood as being the pervasive and all-encompassing power vested in the legislative branch of government. Local governments can only wield the power if it is delegated to them by the national legislature through enabling laws. This delegated power is not a power of eminent domain, but only of inferior domain and is as broad or confined as the real authority wants it to be.

5. The recovery of possession of property taken for public use prayed for by the landowners was denied. The landowners are only entitled to demand the fair market value of the expropriated lots. The right of the expropriatory authority is far from that of an unpaid seller in ordinary sales, to which the remedy of rescission might apply. After condemnation, the paramount title is in the public under a new and independent title.

6. The RTC has acted beyond its lawful cognizance by ordering the payment of just compensation for the expropriated property. The only authority left for the RTC is to order the execution of its decision.

7. Private respondents are not entitled to the return of the expropriated property. However, they deserve prompt payment of the yet unpaid award of just compensation already fixed by final judgment.

PRINCIPLES:

• Curative statutes are retroactive.

• The power of eminent domain is an ultimate right of the sovereign power to appropriate property for a public purpose.

• Expropriation proceedings are not adversarial and do not require the condemning authority to assert conflicting interests in the property.

• In expropriation proceedings, just compensation must be given to the private owner of the property.

• The determination of "public use" in expropriation cases can be based on public employment or actual use by the public and public advantage or benefit.

• Once property is expropriated, the condemnor has the right to decide the use of the property for public use.

• The power of eminent domain can only be exercised by local governments if it is delegated to them by the national legislature through enabling laws.

• Landowners are not entitled to recover possession of expropriated lots, but only to demand the fair market value of the same.

• Condemnation proceedings provide a judicial process for securing better title against all the world than may be obtained by voluntary conveyance.

• The constitutional limitation of "just compensation" is the sum equivalent to the market value of the property.

• Interests on the just value of the property should be included in the final compensation if the property is taken before compensation is deposited with the court.

• The authority of the court after the finality of an expropriation judgment is limited to the execution of the decision. The court cannot modify or revise the judgment.

• After the finality of an expropriation judgment, the rightful owner of the expropriated property is not entitled to its return. They are only entitled to prompt payment of just compensation.