Case Digest (G.R. No. 139495) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mactan-Cebu International Airport Authority (MCIAA) vs. Court of Appeals and Virginia Chiongbian, G.R. No. 139495, decided on November 27, 2000, the Supreme Court reviewed a reconveyance suit involving Lot 941 in Lahug, Cebu City, measuring 13,766 square meters. Originally covered by TCT No. 120366 in MCIAA’s name, the property had been part of the former Lahug Airport. Following U.S. Army occupation during World War II, the land was turned over in 1947 to the Philippine Government via the Surplus Property Commission, later administered by the Bureau of Aeronautics, then the National Airports Corporation, and finally the Civil Aeronautics Administration (CAA). On April 16, 1952, the CAA filed Civil Case No. R-1881, expropriating Lot 941 and other parcels for airport expansion. In June 1953, Virginia Chiongbian purchased Lot 941 from Antonina Faborada for ₱8,000 and obtained TCT No. 9919. On December 29, 1961, the Court of First Instance of Cebu condemned Lot 941 in fee simple Case Digest (G.R. No. 139495) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Property and Ownership History
- Lot 941 (13,766 sq. m.) in Lahug, Cebu City, originally covered by TCT No. 120366 in MCIAA’s name.
- During WWII, Lahug Airport was occupied by the U.S. Army; in 1947 turned over to the Philippine Government via Surplus Property Commission.
- Chain of Title and Expropriation
- Transferred sequentially to Bureau of Aeronautics, National Airports Corporation, and Civil Aeronautics Administration (CAA).
- On April 16, 1952, Republic of the Philippines (CAA) filed expropriation case No. R-1881 including Lot 941 for airport expansion.
- Chiongbian’s Acquisition and Expropriation Judgment
- In June 1953, Virginia Chiongbian purchased Lot 941 from Antonina Faborada for ₱8,000; TCT No. 9919 issued in her name.
- December 29, 1961 judgment in R-1881 condemned Lot 941 to the Republic for ₱34,415 with interest from November 16, 1947; title transferred under TCT No. 27696.
- Creation of MCIAA and Property Transfer
- Republic Act No. 6958 (1990) created MCIAA; assets of Lahug Airport, including Lot 941, transferred by TCT No. 120366 (May 8, 1992).
- Lahug Airport closed end of 1991; all operations moved to Mactan International Airport; Lot 941 remained unused.
- Reconveyance Proceedings
- July 24, 1995 – Chiongbian filed reconveyance suit (RTC CEB-17650) alleging a right of repurchase upon airport abandonment.
- June 3, 1997 – RTC ordered MCIAA to reconvey Lot 941 upon reimbursement of expropriation price; CA affirmed.
- MCIAA’s petition for review raised grounds on Statute of Frauds, parol evidence, Limbaco applicability, and co-defendants’ compromise judgments.
- Chiongbian challenged petition’s certification of non-forum shopping, claiming signatory lacked authority.
Issues:
- Procedural
- Was the petition’s Verification and Certification against forum shopping valid?
- Substantive
- Did the abandonment of the public use for which Lot 941 was expropriated entitle Chiongbian to reacquire it?
- Was there a valid repurchase agreement or reserved condition in the expropriation judgment?
- Could parol evidence be admitted to prove or modify a judicial decision?
- Are the rulings in Limbaco and co-defendants’ modified judgment in CA-G.R. No. 33045-R applicable to Chiongbian?
- If a repurchase right exists, should it follow terms given to other landowners (₱34,415) or prevailing market value?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)