Case Digest (G.R. No. 155746) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1964, the Province of Cebu donated 210 lots to the City of Cebu, including Lot No. 1029 (4,048 sq. m.) in Capitol Hills. In 1965, Diosdado, Doroteo and Ursula Lagcao purchased Lot 1029 on an installment basis, only to have the parcel revert to the province later that year. The Province then sought to annul the sale, prompting the Lagcaos to sue for specific performance and damages in the Court of First Instance. On July 9, 1986, that court ordered the province to execute a final deed of sale in their favor, a decision affirmed by the Court of Appeals on June 11, 1992. On June 17, 1994, the province executed an absolute sale and Transfer Certificate of Title No. 129306 was issued to the petitioners. Upon attempting possession, the Lagcaos found the lot occupied by informal settlers. They instituted ejectment proceedings on June 15, 1997; the Municipal Trial Court in Cities (Branch 1, Cebu City) ordered the squatters to vacate on April 1, 1998, a decision the RTC affirmed with Case Digest (G.R. No. 155746) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Donation and Purchase of Lot 1029
- 1964 – Province of Cebu donated 210 lots (including Lot 1029, 4,048 sq m) to the City of Cebu.
- 1965 – Petitioners purchased Lot 1029 on an installment basis.
- Reversion and Acquisition of Title
- Late 1965 – All 210 lots reverted to the Province of Cebu; the province sought to annul the sale to petitioners.
- 1986 – Court of First Instance ordered specific performance in favor of petitioners.
- 1992 – Court of Appeals affirmed.
- 1994 – Province executed a deed of absolute sale; TCT No. 129306 issued in petitioners’ names.
- Ejectment Proceedings and Legislative Acts
- 1997–1998 – Petitioners filed ejectment against squatters; MTCC and RTC ordered eviction, issuance of writ of execution and demolition order.
- Early 1999 – Mayor Garcia requested suspension of demolition; MTCC suspended demolition for 120 days.
- May 1999 – Sangguniang Panlungsod (SP) resolution identified Lot 1029 as a socialized housing site under RA 7279.
- June 1999 – SP passed Ordinance No. 1772 amending zoning to include socialized housing sites.
- July 2000 – SP enacted Ordinance No. 1843 authorizing expropriation of Lot 1029 for socialized housing, appropriating ₱6,881,600; approved by the mayor August 2, 2000.
- August 2000 – Petitioners filed an action in RTC for nullity of Ordinance 1843; RTC dismissed complaint July 1, 2002; motion for reconsideration denied August 26, 2002.
Issues:
- Whether Ordinance No. 1843 violated the constitutional guarantee against deprivation of property without due process and the requirement of public use.
- Whether the City complied with (a) RA 7160 Section 19 (prior valid and definite offer) and (b) RA 7279 Sections 9–10 (priority in acquisition and exhaustion of modes before expropriation).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)