Case Digest (G.R. No. 124699) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bogo-Medellin Milling Co., Inc. v. Court of Appeals and Heirs of Magdaleno Valdez Sr., decided on July 31, 2003 under the 1987 Constitution, the heirs of Magdaleno Valdez Sr. (Sergio Valdez, Angelina Valdez-Novabos, Teresita Argawanon-Mangubat, and Daylinda Argawanon-Melendres) sued petitioner Bogo-Medellin Milling Co., Inc. (“Bomedco”) before the Regional Trial Court of Cebu City in June 1989 for payment of compensation and/or recovery of possession of a one-hectare parcel (Tax Declaration No. 3935) in Barrio Dayhagon, Medellin, Cebu. Magdaleno Valdez Sr. had purchased the land on December 9, 1935, although railroad tracks owned by Bomedco already traversed its middle. Upon Valdez’s death in 1948, his heirs succeeded to the property, but were unaware that in 1965 Bomedco had it subdivided into Cadastral Lots 953, 954 and 955 and had Lot 954 (the strip with tracks) registered and declared in its name. The heirs discovered this in 1989, demanded justification and compensation, Case Digest (G.R. No. 124699) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Pre-1935 Background
- In 1929, Feliciana Santillan granted Bogo-Medellin Milling Co., Inc. (Bomedco) a 30-year railroad right of way (ROW) over her Dayhagon, Medellin, Cebu lands; tracks were used to haul sugarcane to the mill.
- On December 9, 1935, Santillan sold to Magdaleno Valdez, Sr. an unregistered one-hectare, 34-are, 16-centare parcel traversed by those tracks; Valdez, Sr. took possession and declared the land for tax purposes in his name.
- Post-Sale Events and Cadastral Registration
- Upon Valdez, Sr.’s death in 1948, his heirs (Sergio Valdez, Angelina Valdez-Novabos, Teresita Argawanon-Mangubat and Daylinda Argawanon-Melendres) inherited the property.
- In 1965 cadastral survey, the land was divided into Lots 953, 954 and 955; Lots 953 and 955 remained in the heirs’ names, while Lot 954 (the narrow strip with the tracks) was registered and taxed in Bomedco’s name.
- Discovery and Initial Litigation
- In 1989, the heirs learned of Bomedco’s claim over Lot 954 through the Bureau of Lands; their demands for explanation and compensation went unanswered.
- On June 8, 1989, the heirs filed before the Regional Trial Court (RTC) of Cebu City a “Complaint for Payment of Compensation and/or Recovery of Possession of Real Property and Damages with Application for Restraining Order/Preliminary Injunction” against Bomedco, alleging expiration in 1959 of the original ROW grant and demanding rightful ownership or compensation.
Issues:
- Whether Bomedco acquired ownership of Lot 954 by extraordinary acquisitive prescription (Art. 1137, Civil Code).
- Whether Bomedco acquired ownership or merely an easement by ordinary prescription (Art. 620, Civil Code).
- Whether the heirs’ claims are barred by laches.
- Whether the heirs are entitled to recovery of possession, compensation, and attorney’s fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)