Case Digest (G.R. No. L-41621)
Facts:
The petition arises from the expropriation of Lot No. 988 of the Banilad Estate in Cebu City, originally covered by TCT No. 27692 and owned by the predecessors-in-interest of respondents Benjamin Tudtud et al. In 1949, the National Airports Corporation (NAC) instituted Civil Case No. R-1881 before the Court of First Instance to expand the Lahug Airport by acquiring several adjoining lots, including Lot No. 988. Pursuant to the judgment, TCT No. 27692 was canceled and replaced by TCT No. 27919 in the name of the Republic of the Philippines. No airport structures were erected on Lot No. 988. The property later passed to the Air Transport Office and, by virtue of Republic Act No. 6958 in 1990, to the Mactan-Cebu International Airport Authority (MCIAA). After the opening of the Mactan International Airport, Lahug Airport was closed and its surrounding lots were sold to private developers. On October 7, 1996, Lydia Adlawan, attorney-in-fact for the original owners, demanded that theCase Digest (G.R. No. L-41621)
Facts:
- Pre-expropriation ownership and acquisition
- The predecessors‐in-interest of respondents owned Lot No. 988, covered by TCT No. 27692 in Cebu City.
- In 1949, the National Airports Corporation (NAC) sought to expand Cebu Lahug Airport, acquiring adjacent lots by negotiated sale or expropriation.
- Expropriation proceedings and title transfers
- In Civil Case No. R-1881 (CFI), the NAC obtained a final judgment expropriating Lot No. 988; TCT No. 27692 was cancelled, and TCT No. 27919 was issued to the Republic of the Philippines.
- No airport structures were erected on the expropriated lot; it was later transferred to the Air Transport Office and, in 1990 via RA 6958, to Mactan-Cebu International Airport Authority (MCIAA).
- Closure of Lahug Airport and demand for repurchase
- Upon opening Mactan International Airport, Lahug Airport was closed and portions of the site sold to Cebu Property Ventures, Inc.
- On October 7, 1996, respondents’ attorney-in-fact demanded repurchase of Lot 988 at original price, asserting the airport-use purpose had ceased.
- Judicial proceedings up to the Supreme Court
- Respondents filed RTC Civil Case No. CEB-19464 for reconveyance and damages; MCIAA denied any conditional reversion right.
- Trial court (Branch 20, RTC Cebu) credited witnesses testifying to NAC’s verbal assurance of repurchase and ordered reconveyance.
- The Court of Appeals (May 8, 2006) affirmed; MCIAA’s motion for reconsideration was denied. MCIAA then filed a petition for review with the Supreme Court.
Issues:
- Nature and conditions of the expropriation decree
- Did the judgment in Civil Case No. R-1881 vest absolute, unconditional fee simple title in the government?
- Does the expropriation decree contain an implied condition of reversion upon abandonment of airport use?
- Admissibility of parol evidence and Statute of Frauds
- Does the Statute of Frauds (Art. 1403[2][e], Civil Code) bar respondents from proving verbal assurances of repurchase?
- Is parol evidence admissible to demonstrate an implied condition in an expropriation proceeding?
- Conclusive effect of the Torrens title
- Is TCT No. 27919 conclusive proof of absolute government ownership, precluding any reversionary right?
- Did the Court of Appeals err in allowing evidence beyond the Torrens title?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)