Title
Padayao vs. Villafuerte
Case
G.R. No. 260415
Decision Date
Jan 15, 2025
Dante Padayao appealed a CA ruling limiting possession to Lot No. 6973. The Supreme Court ruled he also has rights to Lot No. 6972, reinstating his possession.

Case Digest (G.R. No. 260415)
Expanded Legal Reasoning Model

Facts:

  • Parties and Subject Property
    • Petitioner Dante Padayao, Punong Barangay, represents the Heirs of Mario Padayao who own Pitogo Island, Caramoan, Camarines Sur, consisting of Lot Nos. 6972 and 6973.
    • Lot No. 6973 is covered by Katibayan ng Orihinal na Titulo Blg. 35669 (KOT Blg. 35669) in the petitioners' name, with an area of 74,407 square meters.
    • Respondents include Gov. Luis Raymund F. Villafuerte, Jr., co-respondents Atty. Janis Ian Regaspi-Cleofe, Jose Francisco L. Musa, Jr., Luis Zulueta, Jovie Villareal, Dondon Obias, and the Provincial Government of Camarines Sur.
  • Incident of Eviction and Demolition
    • On January 6, 2009, the Provincial Government notified residents including Rowel Padayao to vacate Pitogo Island within 10 days claiming it as a protected and danger zone.
    • On January 20, 2009, armed men accompanied respondents and compelled residents to vacate the premises, threatening demolition.
    • The demolition was executed on February 4, 2009 by the Provincial Government, removing all structures including petitioner’s.
  • Evidence Presented by Petitioner
    • Testimony of Dante and his predecessors proving possession since 1920 in the concept of an owner.
      • Office of Municipal Treasurer's Certification showing payment of real property taxes from 1945 to 2009.
      • Survey Plan from 1934 in favor of Julio Padayao.
    • Testimony of Fr. Joaquin Camano witnessing demolition.
    • Protected Area Management Board (PAMB) confirmed Pitogo Island was not a DENR protected area.
    • Testimony of Manuel Tengco, DENR official, confirming Pitogo Island as alienable and disposable land based on Land Classification Cadastral Map 882 and other DENR certifications.
  • Evidence Presented by Respondents
    • Jovie Villareal testified he negotiated residents to vacate with financial assistance offers.
      • Except the Padayaos, all residents agreed to leave.
    • Jose Francisco L. Musa, Jr., oversaw the demolition, declaring the area a danger zone.
    • Studies by Arturo Manamtam and Kevin Pacifico highlighted ecological threats and recommended Pitogo Island's declaration as a protected area.
    • The respondents posited the eviction was the exercise of police power for environmental protection.
  • Proceedings
    • RTC granted preliminary mandatory injunction to Dante on May 16, 2012.
    • RTC Decision (April 27, 2018) ordered respondents to vacate and restore possession of both Lot Nos. 6972 and 6973 to Dante.
    • Respondents' motion for reconsideration was denied by RTC on September 25, 2018.
    • CA affirmed RTC decision with modification on May 25, 2021, recognizing Dante’s possession only over Lot No. 6973.
    • Petitioner filed the present appeal contesting partial denial.

Issues:

  • Whether Dante Padayao has a better right of possession over both Lot Nos. 6972 and 6973 or only over Lot No. 6973.
  • Whether Pitogo Island is alienable and disposable land or a protected area.
  • Whether the court has jurisdiction given the nature of the complaint and assessed value of property.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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