Title
Mazy's Capital, Inc. vs. Republic
Case
G.R. No. 259815
Decision Date
Aug 5, 2024
Mazy's sought a review of a CA decision that remanded a cancellation case due to alleged misrepresentations in reconstitution proceedings, raising ownership and just compensation issues.

Case Digest (G.R. No. 254021)
Expanded Legal Reasoning Model

Facts:

  • Background and Property Description
    • The case concerns Lot No. 937, a 46,143-square meter parcel located in Cebu City, part of the Banilad Friar Lands Estate.
    • The Banilad Friar Lands have a history of multiple ownership disputes reaching the Supreme Court.
  • 1938 Expropriation Proceedings (Civil Case No. 781)
    • The Commonwealth of the Philippines filed an expropriation complaint against various Friar Lands owners for use by the Armed Forces under the National Defense Act.
    • Lot 937 was registered to Eutiquio Uy Godinez, married to Felisa Sy Cip.
    • The Commonwealth valued Lot 937 provisionally at PHP 1,845.72, deposited PHP 9,500 as payment for all lots, and supposedly took possession.
    • Felisa, administratrix of Eutiquio's estate, accepted PHP 1,845.72 as just compensation in 1939, supported by a CFI Decision Parcial and a Provincial Voucher dated May 25, 1939.
    • The CFI rendered a decision in 1940 confirming payments for other lots but considered Lot 937 resolved by the 1939 partial decision.
    • World War II disrupted possession and ownership, leading to subsequent ownership controversies.
  • 1954 Reconstitution of Title (G.L.R.O. Record No. 5988)
    • Ramona U. Agustines, purportedly attorney-in-fact for Mariano Godinez (Eutiquio's son), filed a petition for reconstitution claiming loss of records and registered ownership of Mariano.
    • The CFI granted the petition in 1956, issuing reconstituted TCT No. RT-6757 in Mariano’s name based on a technical description, a tax declaration in Eutiquio's name, and a survey plan.
  • 1997 Reivindicatoria Action (Civil Case No. CEB-19845)
    • Mariano’s supposed attorneys-in-fact filed a reivindicatoria to claim ownership of Lot 937, alleging Philippine National Police construction and possession without just compensation by the Republic.
    • RTC Branch 9 ruled in favor of Mariano in 2002, holding that the Republic failed to prove just compensation payment.
    • The Court of Appeals affirmed, noting lack of evidentiary weight on the 1939 partial decision due to language issues.
    • Numerous subsequent legal actions were taken, including filings by Archangels Residents and AFP members, challenging possession and titles over Lot 937.
  • Present Cancellation Case (Civil Case No. CEB-39718)
    • In 2013, the Republic (through DND) filed a complaint for cancellation of the reconstituted title based on allegations that the expropriation court already awarded Lot 937 to the Republic and just compensation was paid.
    • The Republic claimed Mariano and his agent misrepresented possession and non-encumbrance, leading to fraud in the reconstitution.
    • Marcos Mazy’s Capital, Inc. purchased Lot 937 from Mariano in 2018, obtained a new TCT (No. 107-2018002380), and joined as defendant in the cancellation case.
    • RTC Branch 12 dismissed the complaint, ruling issues were barred by res judicata; the Court of Appeals reversed and remanded.
  • Discovery and Judicial Proceedings
    • The Court undertook ocular inspection of Lot 937 and the original records of the Expropriation Case and Reconstitution Case.
    • A Provincial Voucher evidencing payment of just compensation to Felisa Sy Cip was discovered in the Expropriation Case records.

Issues:

  • Whether the reconstitution of title issued to Mariano was valid and lawful.
  • Whether the Republic had paid just compensation for Lot 937 during expropriation proceedings.
  • Whether the decision in the 1997 Reivindicatoria Case adjudging Mariano as owner is final and binding (res judicata).
  • Whether RTC Branch 12 had jurisdiction over the cancellation complaint.
  • Whether Mazy’s is an innocent purchaser for value of Lot 937.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.