Case Digest (G.R. No. 207791) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Navy Officers’ Village Association, Inc. v. Republic of the Philippines (G.R. No. 177168, August 3, 2015), the Navy Officers’ Village Association, Inc. (NOVAI) held Transfer Certificate of Title No. T-15387 over a 475,009 m² parcel inside the former Fort Andres Bonifacio Military Reservation (FBMR) in Taguig. The Republic of the Philippines, owner of the larger military reservation, filed a complaint on December 23, 1993 before the Regional Trial Court (RTC), Branch 67, Pasig City, seeking cancellation of NOVAI’s title on grounds that the land remained a military reservation, that the sale deed and Proclamation No. 2487 authorizing the titling were fictitious, and that NOVAI never applied properly nor fully paid. NOVAI answered that the property had been excluded from the FBMR by Proclamation No. 461 (September 29, 1965), purportedly applied under Republic Acts Nos. 274 and 730, and that any irregularity was formal and subject only to reformation. On August 20, 2004 the RTC d Case Digest (G.R. No. 207791) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Land and Title
- TCT No. T-15387 covers a 475,009 sqm parcel inside the former Fort William McKinley/Fort Andres Bonifacio, originally under TCT No. 61524 in the Republic’s name.
- Presidential Proclamations:
- No. 423 (1957) established the FBMR military reservation.
- No. 461 (Sept. 1965) excluded 2,455,310 sqm for an AFP Officers’ Village.
- No. 478 (Oct. 1965) reserved 537,520 sqm (including the property) for the Veterans Rehabilitation, Medicare and Training Center.
- Deed of Sale and Registration
- On November 15, 1991, the Republic, through LMB Director Abelardo Palad Jr., purportedly sold the property to NOVAI for ₱14,250,270, citing Proclamation No. 2487 as authority.
- NOVAI paid partial installments and secured TCT No. T-15387 on January 9, 1992.
- Judicial Proceedings
- 1993 RTC Complaint by Republic to cancel NOVAI’s title for (a) military-reservation status, (b) fictitious deed, (c) lack of sale records, and (d) forged proclamation.
- RTC (2004) dismissed complaint and upheld NOVAI’s indefeasible title; CA (2006) reversed, declaring the land inalienable and sale void; SC (2015) denied NOVAI’s petition for review.
Issues:
- Whether the property remained an inalienable public-domain reservation under Proclamation No. 478.
- Whether Proclamation No. 2487 and the deed of sale by LMB Director Palad were valid.
- Whether NOVAI’s Torrens title attained indefeasibility and barred cancellation by prescription.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)