Estate of Salud Jimenez v. Philippine Export Processing Zone

Summary

This case involves the rescission of a compromise agreement in expropriation proceedings initiated by PEZA against the Estate of Salud Jimenez. After PEZA's expropriation order became final in 1991, parties agreed to swap the condemned Lot 1406-B for PEZA's Lot 434. When PEZA failed to deliver Lot 434 (which it didn't own), the estate sought rescission. The trial court rescinded the agreement and ordered return of the expropriated property, but the Supreme Court ruled this was grave abuse of discretion since the expropriation order was final and executory. The Court affirmed PEZA's constitutional authority to expropriate for public use and held that only the payment arrangement, not the right to expropriate, was subject to the compromise. The case was remanded for just compensation proceedings, emphasizing that prompt payment is essential to due process in eminent domain cases.