Petitioner
Local Government of Quezon City
Respondent
Sy
Citation
G.R. No. 202753
Court
Supreme Court
Division
Second Division
Decided
March 4, 2013

Liability for exemplary damages and attorney's fees in expropriation proceedings involving delayed payment and improper procedures

Summary

This expropriation case involves the Local Government of Quezon City's improper taking of Henry L. Sy's property. The government took possession in 1986 but only approved the expropriation ordinance in 1994 and filed the complaint in 1996, creating a 10-year delay in following proper procedures. The Court of Appeals awarded exemplary damages and attorney's fees against the government. The Supreme Court denied the petition for review and motion for reconsideration, affirming that the government's wanton acts in occupying property without proper expropriation proceedings or immediate payment as required by RA 8974 and the Local Government Code warranted exemplary damages. The Court emphasized that the length of delay is immaterial; what matters is the presence of improper government conduct requiring correction.

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By Intellegal Editorial Board · March 4, 2013

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