Case Digest (G.R. No. 176625) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The subject of this dispute is Lot No. 88-SWO-25042, a 1,017-square-meter parcel in Lahug, Cebu City, originally owned by Anastacio Deiparine and later conveyed to respondent Bernardo L. Lozada, Sr., who received TCT No. 9045. In Civil Case No. R-1881 before the Court of First Instance of Cebu (Third Branch), the Republic of the Philippines, represented by the Civil Aeronautics Administration (CAA), sought to expropriate the lot for the expansion of Lahug Airport. On December 29, 1961, the trial court granted the petition, fixing just compensation at ₱3.00 per square meter plus legal interest from November 16, 1947. Lozada received ₱3,018.00 and lodged an appeal. During the appeal, the CAA (later the Air Transportation Office) verbally promised that if the airport expansion were abandoned, the expropriated lots would be offered back to their former owners at the original price. Reliant on this assurance, Lozada withdrew his appeal. Title was then transferred to the Republic unde Case Digest (G.R. No. 176625) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Expropriation and Ownership
- Lot No. 88-SWO-25042 (1,017 sqm) in Lahug, Cebu City originally owned by Anastacio Deiparine; occupied by U.S. Army since 1947 and turned over to Civil Aeronautics Administration (CAA).
- Republic (through CAA) filed Civil Case No. R-1881 before the CFI of Cebu for airport expansion; judgment on December 29, 1961 condemned the lot at ₱3.00/sqm (₱3,018 total) plus legal interest; Transfer Certificate of Title No. 9045 issued to Bernardo L. Lozada, Sr.
- Compromise Agreement and Airport Abandonment
- During appeal, Air Transportation Office (ATO) (formerly CAA) proposed that affected owners withdraw appeals in exchange for a commitment to resell at the expropriation price if Lahug Airport were abandoned; Lozada relied on this and did not pursue his appeal; title transferred to the Republic (TCT No. 25057).
- Lahug Airport expansion never materialized; President Aquino’s November 29, 1989 memorandum directed transfer of general aviation to Mactan Airport before year-end; RA 6958 (1990) created MCIAA and vested it with both airports; Lahug Airport closed and the site converted into Bagong Buhay Rehabilitation Complex and Ayala I.T. Park.
- Recovery Proceedings
- On June 4, 1996 respondents filed Civil Case No. CEB-18823 for recovery of Lot No. 88, alleging (a) prior ownership, (b) expropriation and oral compromise to repurchase if airport abandoned, (c) abandonment of public purpose, and (d) right to reconveyance; petitioners denied any binding agreement and asserted fee-simple title.
- Parties stipulated key facts (lot identity, expropriation, public purpose, transfer to MCIAA, airport closure directive); RTC Branch 57, Cebu City rendered decision on October 22, 1999 ordering reconveyance upon repayment; CA denied petitioners’ appeal in its February 28, 2006 Decision and denied reconsideration on February 7, 2007; this petition for review followed.
Issues:
- Did respondents prove a binding oral compromise agreement obliging the Government to resell Lot No. 88 upon abandonment of the Lahug Airport?
- Whether the condemnation decree granted fee-simple title to the Republic, thereby extinguishing respondents’ reversion rights despite non-use?
- Whether respondents’ enforcement of the oral assurances is barred by the Statute of Frauds?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)