Case Digest (G.R. No. 197743)
Facts:
Heirs of Jose Mariano and Helen S. Mariano, represented by Danilo David S. Mariano, Mary Therese Irene S. Mariano, Ma. Catalina Sophia S. Mariano, Jose Mario S. Mariano, Ma. Lenor S. Mariano, Macario S. Mariano and heirs of Erlinda Mariano‑Villanueva, represented in this act by Irene Lourdes M. Villanueva through her attorney‑in‑fact Editha S. Santuyo and Benjamin B. Santuyo, petitioners v. City of Naga, G.R. No. 197743, March 12, 2018, Supreme Court First Division, Tijam, J., writing for the Court.
The dispute concerns a 5‑hectare portion of a larger subdivision (TCT No. 671) that the subdivision promoters allegedly offered to donate in 1954 to the City of Naga as sites for the City Hall (2 ha), public plaza (2 ha) and market (1 ha). The Subdivision’s officers sent letters and the Municipal Board adopted resolutions accepting an amended offer to donate five hectares and authorized the mayor to execute a deed of donation. The City thereafter occupied the site and government agencies built offices thereon. The City later declared the land in its name for tax purposes.
Petitioners (heirs of registered owner Macario Mariano) claim the donation never consummated because the condition — that the Subdivision be awarded the construction contract for the City Hall — was not fulfilled when the Bureau of Public Works awarded the contract to another contractor (Sabaria). They allege Macario repeatedly sought return or purchase of the lot, and the family never received payment; Macario died in 1971. Following probate events, petitioners in 2004 demanded the City vacate; when it did not, they filed an unlawful detainer complaint in the Municipal Trial Court (MTC), Branch 1, Naga City (Civil Case No. 12334), seeking restitution of possession, P2.5 million monthly reasonable compensation, and attorney’s fees.
The MTC (Feb. 14, 2005) gave weight to an alleged Deed of Donation but dismissed the complaint for lack of jurisdiction because ownership questions were raised. The Regional Trial Court (RTC), Branch 26, Naga City (June 20, 2005), on appeal reversed the MTC, found no valid deed of donation (award of contract released donors from obligation), held the City possessed the lot by mere tolerance and had built in bad faith, and ordered the City and agencies to vacate, to pay P2,500,000.00 per month from Nov. 30, 2003 until vacation, attorney’s fees, and costs.
The Court of Appeals (CA) partly granted the City in a March 7, 2011 decision: it modified the RTC award, reducing the monthly award to P250,000.00 for petitioners (half of a P500,000.00 figure it adopted) and deleting the order against other government instrumentalities because they were not parties; the CA affirmed other aspects. Upon motions for reconsideration the CA issued an Amended Decision (July 20, 2011) that granted the City’s reconsideration, annulled the RTC decision, reinstated the MTC dismissal, and excluded consideration of certain secondary evidence under the best‑evidence rule; it also found petitioners guilty of laches and admitted secondary evidence of the Deed only as exception to the best evidence rule due to purported destruction of no...(Pro-only)
Issues:
- Did the CA correctly admit secondary evidence (photocopies) and thereby establish a valid Deed of Donation when the original deed was not presented?
- Was the purported Deed of Donation valid and, if not, does the City have a superior right to possession over petitioners (heirs of the registered owner)?
- Were petitioners’ claims barred by laches or prescription?
- What relief is proper in an unlawful detainer case here — restitution, reasonable compensation (rent), and attorney’s fees — and are government a...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)