Case Digest (G.R. No. 158791)
Facts:
In Heirs of Jose Mariano and Helen S. Mariano v. City of Naga (G.R. No. 197743, March 12, 2018), petitioners are the heirs of Macario S. Mariano and Erlinda M. Mariano-Villanueva, represented by Danilo David S. Mariano and others. In July 1954, City Heights Subdivision, managed by Eusebio M. Lopez Sr. and associates, offered to donate two hectares for a city hall if it built the same, later amending this to a five-hectare donation (subject property) on lands titled to Macario and Jose A. Gimenez under TCT No. 671. The Municipal Board of Naga passed Resolutions Nos. 75 and 89 accepting the amended offer and authorizing donation. Petitioners claim the condition (subdivision’s construction contract) failed when the Bureau of Public Works awarded the project in 1959 to an outsider, Francisco O. Sabaria, and the deed of donation was never perfected. Macario demanded return or sale of the property but died in 1971 unpaid. His heirs engaged in succession and adoption disputes, culminatCase Digest (G.R. No. 158791)
Facts:
- Offer and proposed donation
- July 3, 1954 – Officers of City Heights Subdivision offered to donate ≥2 ha for a City Hall site on condition the subdivision be awarded the construction contract; City free to accept other offers.
- July 12 & 30, 1954 – Naga Municipal Board requested a larger site; subdivision amended its offer to donate 5 ha (2 ha City Hall, 2 ha plaza, 1 ha market), signed by registered owners Macario Mariano and Jose Gimenez with spouses’ consent.
- August 11, 1954 – Municipal Board adopted Resolution No. 89 accepting the donation proposal and authorizing the mayor to execute the deed of donation.
- Divergent accounts of execution and use
- City’s version – On August 16, 1954 Mayor Imperial and the landowners executed a Deed of Donation; City took possession, built the government center, declared the 5 ha for tax purposes, and allowed other agencies (LTO, NBI, DOLE, PPC, Fire Department) to occupy.
- Petitioners’ version – The construction contract was awarded to Sabaria by the Bureau of Public Works; the subdivision’s promise to build was aborted, invalidating the donation condition; Macario demanded return or purchase (1959, 1968) but City failed to compensate; Macario died in 1971 unpaid.
- Heirs and estate proceedings
- Post-1971 – Partition and adoption disputes over Macario’s estate; Irene’s estate probated in 1997, letters of administration issued to Danilo Mariano.
- 2003–2004 – Danilo demanded that Mayor Robredo vacate the property; petitioners filed an unlawful detainer Complaint (MTC 12334) in February 2004 seeking ejectment, possession return, P2.5 M/mo rent from demand, and attorney’s fees.
- Procedural history
- MTC (Feb 2005) – Dismissed Complaint for lack of jurisdiction, finding ownership issue beyond its scope.
- RTC (June 20, 2005) – Reversed MTC, ordered City and all agencies to vacate, surrender possession, pay P2.5 M/mo from Nov 30, 2003, attorney’s fees (P587,159.60) and costs; held no valid donation, no laches, City in bad faith.
- CA (Mar 7, 2011) – Partially granted City’s appeal: reduced rent to ₱250,000/mo (half share), deleted non-party relief, cut attorney’s fees to ₱200,000.
- CA Amended (July 20, 2011) – Granted City’s reconsideration, annulled RTC decision, reinstated MTC dismissal; denied heirs’ motion.
Issues:
- Has the City a better right to possession under unlawful detainer, based on the 1954 Deed of Donation?
- Is the Deed of Donation valid under Article 749, Civil Code, and notarial formalities?
- Are petitioners’ claims barred by laches or prescription?
- Does subdivision “open space” designation vest automatic ownership in the City?
- Is the City a builder in good faith entitled to retain improvements or receive indemnity?
- What constitutes reasonable compensation, rent and attorney’s fees in this case?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)