Case Digest (G.R. No. 156273)
Facts:
Heirs of Timoteo Moreno and Maria Rotea, et al. v. Mactan‑Cebu International Airport Authority, G.R. No. 156273, October 15, 2003, the Supreme Court Third Division, Bellosillo, J., writing for the Court.The petitioners are the heirs of the former registered owners of Lots Nos. 916 and 920 in Lahug, Cebu City (TCT Nos. RT‑7543 and RT‑7544), which were the subject of an expropriation action filed by the Civil Aeronautics Administration (predecessor of respondent Mactan‑Cebu International Airport Authority (MCIAA)) in 1952 (Civil Case No. R‑1881) for the expansion of Lahug Airport. The trial court condemned the lots on 29 December 1961 and awarded just compensation (P7,065.00 for Lot 916; P9,291.00 for Lot 920). No appeal was taken and titles were later issued to the Republic and subsequently transferred to MCIAA under RA 6958.
Although the expropriation was effected, petitioner‑owners allege that government officers had orally assured landowners they could repurchase their lands if Lahug Airport were later closed or operations transferred to Mactan. Some owners sold with written repurchase rights; others refused low offers. By the early 1990s Lahug Airport ceased operations after Mactan Airport opened, and the expropriated lots remained unused. Petitioners sought to exercise the alleged right of repurchase but were rebuffed.
On 11 March 1997 petitioners filed Civil Case No. CEB‑20015 for reconveyance and damages in the Regional Trial Court (RTC), Branch 19, Cebu City, alleging the government’s assurance and seeking reconveyance. Intervenors included Richard E. Enchuan (claiming assignment of rights from some petitioners) and the Department of Public Works and Highways (DPWH) claiming a lease and improvements on Lot 920. On 12 April 1999 the RTC granted petitioners’ claim, recognizing a right of repurchase but subject to Enchuan’s claimed rights and DPWH’s leasehold; the trial court held the expropriation had become illegal or functus officio when its public purpose ceased.
MCIAA appealed to the Court of Appeals (CA‑G.R. CV No. 64456). On 20 December 2001 the Court of Appeals reversed, finding the condemnation judgment in Civil Case No. R‑1881 was unconditional and conveyed fee simple title to the Republic, thus precluding repurchase; it rel...(Subscriber-Only)
Issues:
- Were petitioners’ proofs admissible and sufficient to support a right of repurchase despite the final judgment of condemnation?
- Does the cessation of the public purpose (closure/abandonment of Lahug Airport) justify reconveyance or repurchase of land expropriated under an apparently unconditional condemnation?
- What remedy and terms should govern reconveyance if a ri...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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