Case Digest (G.R. No. 122947)
Facts:
Timoteo Baluyot, Jaime Benito, Benigno Eugenio, Rolando Gonzales, Fortunato Fulgencio and Cruz‑na‑Ligas Homesite Association, Inc. v. The Honorable Court of Appeals, The Quezon City Government and University of the Philippines, G.R. No. 122947, July 22, 1999, Supreme Court Second Division, Mendoza, J., writing for the Court.The petitioners are residents of Barangay Cruz‑na‑Ligas, Diliman, Quezon City, and the Cruz‑na‑Ligas Homesite Association, Inc. is a non‑stock corporation composed of such residents. On March 13, 1992 the petitioners filed a complaint for specific performance and damages against the University of the Philippines (UP) in the Regional Trial Court (RTC) of Quezon City (Civil Case No. Q‑92‑11663). The complaint was later amended to implead the Quezon City Government. Petitioners alleged long, adverse possession of a larger area (about 42 hectares) and claimed to be intended beneficiaries of a prior deed of donation executed by UP in favor of the Quezon City Government conveying 15.8379 hectares for the benefit of qualified Cruz‑na‑Ligas residents.
The antecedent administrative and quasi‑judicial history included endorsements by the Bureau of Lands and by the Office of the President recognizing the residents’ claims, negotiations in which UP offered to donate c. 9.2 then 15.8 hectares, and litigation in LRC No. 3151 (Branch 100, RTC) where a preliminary injunction was issued then lifted after petitioners agreed to dismissal conditioned on UP’s assurances. UP thereafter executed a Deed of Donation on August 5, 1986 conveying 15.8379 hectares to the Quezon City Government subject to conditions (improvements, relocation, 3‑year period before donation to individual residents, transfer of titles by the Donee, etc.). UP, however, allegedly failed to deliver the certificates of title needed for registration; after the expiration of the prescribed period UP issued Administrative Order No. 21 purporting to revoke the donation and revert the property to UP.
Petitioners sought injunctive relief in the RTC to preserve status quo and to enforce the deed of donation, but on May 15, 1992 the RTC (Branch 89) denied a preliminary injunction, finding petitioners were not parties to the deed of donation and that it had been validly revoked. The RTC nevertheless ordered petitioners to implead Quezon City, which they did. The city answered and later withdrew its cross‑claim, recognizing the alleged validity of the revocation. UP and Quezon City moved to dismiss the amended complaint for failure to state a cause of action; the RTC denied the motion on April 26, 1995, reasoning that petitioners’ allegations might entitle them to ownership by laches and thus required trial on the merits, even while reiterating that petitioners lacked a cause of action for specific performance if the donation had been validly revoked.
Respondents filed a petition for certiorari with the Court of Appeals, alleging grave abuse of discretion in the RTC’s refusal to dismiss. On November 2...(Pro-only)
Issues:
- Did the amended complaint state a cause of action such that dismissal was improper?
- Did petitioners’ pleading constitute an impermissible collateral attack on UP’s registered title, thereby justifying dismissal?
- Were petitioners’ alternative claims (specific performance as intended beneficiaries and claims of ownership/acquisition by laches or prescription) fatally incons...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)