- Petitioner
- Republic of the Philippines
- Respondent
- Holy Trinity Realty Development Corp.
- Citation
- G.R. No. 172410
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Chico-Nazario, J.
- Decided
- April 14, 2008
Summary
The Republic, through TRB, expropriated land for North Luzon Expressway expansion and deposited advance payment with Land Bank per RA 8974 requirements. When landowner HTRDC withdrew its share, dispute arose over ownership of accrued interest. The Supreme Court applied Civil Code accession principles, ruling that since the deposit constituted immediate payment under RA 8974 (not mere deposit under Rule 67), HTRDC became owner of the principal amount and thus entitled to interest as civil fruits. The Court distinguished this from delay damages cases, emphasizing that RA 8974's immediate payment scheme transfers ownership upon deposit. This decision clarifies property ownership rights in government expropriation proceedings and the application of accession principles to bank interest in such contexts.