Case Digest (G.R. No. 197743) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Heirs of Mariano v. City of Naga (G.R. No. 197743, October 18, 2022), the petitioners—heirs of Macario A. Mariano and of Erlinda Mariano-Villanueva—sought possession of a five-hectare parcel covered by Transfer Certificate of Title No. 671 in Naga City. The disputed lot was allegedly donated to respondent City of Naga in a Deed of Donation dated August 16, 1954; however, the instrument bore a defective acknowledgment and lacked proper acceptance, rendering it void. Despite knowing the defect, the City took possession, built its City Hall and housed several national offices on the lot, yet never formalized ownership by expropriation or purchase. In 1997, upon the appointment of an administrator over one heir’s estate, petitioners demanded that the City vacate. They filed an unlawful detainer complaint in February 2004 before the Municipal Trial Court (MTC), which was dismissed for lack of jurisdiction. The Regional Trial Court (RTC) reversed and ordered the City to vacate and Case Digest (G.R. No. 197743) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Ownership and Deed of Donation
- The 22.9301-hectare property under TCT No. 671 is registered in the names of Macario A. Mariano and Jose A. Gimenez (registered owners).
- On July 30, 1954, City Heights Subdivision (CHS), through its officers (including Lopez Jr.) and with the registered owners’ spouses’ marital consent, offered to donate five hectares for the City Hall, plaza, and public market.
- Municipal Resolution No. 89 (Aug 11, 1954) authorized Mayor Monico Imperial to accept the donation; a Deed of Donation was notarized on August 16, 1954.
- Dispute over Validity and Possession
- Petitioners allege the donation was void for failure to comply with the condition that CHS be awarded the construction contract (which was in fact bid out to another contractor).
- CHS’s general manager and one of the registered owners wrote in 1959 and 1968 to demand return or purchase of the lot, but no sale materialized.
- Procedural Antecedents
- September 2003: Petitioners (heirs, as represented by administrator Danilo D. Mariano) demand City of Naga to vacate and return the property.
- February 12, 2004: Petitioners file Complaint for Unlawful Detainer in MTC-Naga Branch I (Civil Case No. 12334), praying for ejectment, return of possession, and P2.5 million/month in rentals.
- February 15, 2005: MTC dismisses for lack of jurisdiction.
- June 20, 2005: RTC-Naga Branch 26 reverses, orders ejectment and payment of rentals.
- July 20, 2011: CA reverses RTC and reinstates MTC dismissal.
- March 12, 2018: SC First Division (First Division Decision) grants petitioners’ ejectment, holding the deed void, directs City and all agencies to vacate, pay P1.25 million/month from Nov 30, 2003, and attorney’s fees P75,000.
- July 23, 2018: First Division denies City’s first motion for reconsideration.
- November 12, 2019: SC grants City leave to file Second Motion for Reconsideration (2nd MR).
Issues:
- Did petitioners’ delay amount to laches, barring their claim to possession or compensation?
- Should the City’s Second Motion for Reconsideration be granted in the higher interest of justice—namely, is payment of just compensation with interest (in lieu of physical recovery) the proper remedy?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)