Case Digest (G.R. No. 158563)
Facts:
In the case of Air Transportation Office (ATO) and Mactan-Cebu International Airport Authority (MCIAA) vs. Apolonio Gopuco, Jr., the respondent, Apolonio Gopuco, Jr., was the owner of Cadastral Lot No. 72, consisting of 995 square meters located near Lahug Airport in Cebu City, under Transfer Certificate of Title (TCT) No. 13061-T. The Lahug Airport was turned over to the Philippine government by the United States Army in 1947, and various administrative bodies managed it over the years, culminating in the establishment of the Civil Aeronautics Administration (CAA). In the late 1940s, the government expressed intentions to expropriate lands around the airport for expansion. While some landowners sold their properties under the pretense of a possible repurchase later, Gopuco resisted selling his lot.
On April 16, 1952, the CAA initiated expropriation proceedings against Gopuco for Lot No. 72 via a complaint filed in the Court of First Instance (CFI) of Cebu, docketed as Civil Ca
Case Digest (G.R. No. 158563)
Facts:
- Respondent Apolonio Gopuco, Jr. owned Cadastral Lot No. 72, covering 995 square meters near Lahug Airport in Cebu City, evidenced by Transfer Certificate of Title No. 13061-T.
- The Lahug Airport, originally under the control of the United States Army, was turned over to the Philippine Government in 1947 through the Surplus Property Commission, later succeeded by various agencies (Bureau of Aeronautics, National Airport Corporation, and Civil Aeronautics Administration).
- In 1949, the National Airport Corporation informed landowners—including Gopuco—that the government was acquiring lands surrounding the airport for its expansion; while some landowners agreed on the promise of repurchase when the facility was no longer needed, Gopuco declined to sell.
Background and Expropriation Proceedings
- On April 16, 1952, the Civil Aeronautics Administration filed a complaint with the Court of First Instance (CFI) of Cebu (Civil Case No. R-1881) seeking expropriation of Lot No. 72 and adjoining properties for airport expansion.
- On December 29, 1961, the CFI rendered a decision:
Initiation of Expropriation and Judicial Proceedings
- With the establishment and commencement of operations of the Mactan International Airport, the Lahug Airport was ordered closed by President Corazon C. Aquino through a memorandum dated November 29, 1989; consequently, Lot No. 72 was virtually abandoned.
- On March 16, 1990, Gopuco addressed a letter to the Bureau of Air Transportation (via the Lahug Airport’s manager), seeking the return of his lot and offering to return the compensation already received; the letter went unanswered.
- In 1990, Congress passed Republic Act No. 6958, which created the Mactan-Cebu International Airport Authority (MCIAA) and provided for the transfer of Lahug Airport’s assets. On May 8, 1992, title to Lot No. 72 was transferred to the MCIAA under TCT No. 120356.
Changes in the Airport’s Status and Subsequent Developments
- On August 6, 1992, Gopuco filed an amended complaint before the Regional Trial Court (RTC) of Cebu, Branch X (Civil Case No. CEB-11914), seeking reconveyance of Lot No. 72 on the ground that the original public purpose for expropriation had ceased due to the closure of the Lahug Airport.
- Gopuco argued that:
Filing of the Recovery Action and Subsequent Court Decisions
Issue:
- Whether the Court of Appeals erred in holding that respondent Gopuco possessed the right to reclaim ownership of Lot No. 72 on the ground that the public use (Lahug Airport) for which the land was expropriated had been abandoned.
- Whether the expropriation judgment in Civil Case No. R-1881, having become final and executory, implied that the property would revert to the former owner upon cessation of the public purpose, notwithstanding the fact that the expropriation was rendered in fee simple without any explicit condition of reversion.
Right to Reclaim the Expropriated Property
- Whether the deletion of the award for litigation expenses and costs in favor of the petitioners (MCIAA) by the Court of Appeals was in error, especially considering the contention that Gopuco’s claim did not meet the threshold for such award.
- Whether there existed any basis, such as bad faith or a clearly unfounded complaint, to impose additional costs on Gopuco.
Award of Litigation Expenses and Costs
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)