FACTS:

The respondents received a Notice of Land Valuation and Acquisition from the Department of Agrarian Reform Provincial Agrarian Reform Office, indicating the compulsory acquisition of a portion of their land. They disputed the valuation made by the Land Bank of the Philippines (LBP) and sought for the determination of just compensation through the Regional Trial Court. The trial court fixed the just compensation at P7.00 per square meter and ordered the immediate deposit of the total amount due to the respondents. The respondents filed a motion for execution pending appeal, which was granted by the trial court. The LBP filed a petition with the Court of Appeals (CA) to question the execution pending appeal, but the CA dismissed the petition and affirmed the trial court's order. The LBP then brought the case to the Supreme Court, which upheld the decision of the CA.

In another case, the CA granted the LBP's appeal and returned the case to the trial court for proper determination of just compensation. The LBP filed a motion for partial reconsideration, arguing that the trial court's decision was voided and could no longer be executed. The CA denied the motion, stating that the validity of the writ of execution was previously resolved by the Supreme Court in a prior case.

ISSUES:

1. Whether or not the writ of execution pending appeal can be implemented in light of the annulment of the valuation made by the Special Agrarian Court (SAC).

RULING:

1. The Court affirmed the decision of the Court of Appeals (CA) and held that the writ of execution pending appeal cannot be properly implemented since the valuation made by the SAC, which served as the basis for the monetary award, was annulled. However, the Court ordered the Land Bank of the Philippines (LBP) to release the compensation offered for the land taken to the respondents, without prejudice to the recomputation of just compensation by the Regional Trial Court (RTC).

PRINCIPLES:

• A void judgment or order has no legal and binding effect

• A void judgment may be entirely disregarded or declared inoperative by any tribunal in which its effect is sought

• A void judgment is regarded as a nullity and leaves the parties in the same position they were in before the trial

• Any writ of execution based on a void judgment is also void

• A void judgment can never be validly executed.

• The release of the offered compensation to the landowner pending the determination of the final valuation of their properties is allowed in expropriation cases.

• Just compensation encompasses not only the correct determination of the amount to be paid to the landowners, but also payment within a reasonable time from the taking of the property.