Case Digest (G.R. No. 260415) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves Punong Barangay Dante Padayao (Petitioner) and various respondents including Gov. Luis Raymund F. Villafuerte, Jr., Atty. Janis Ian Regaspi-Cleofe, Jose Francisco L. Musa, Jr., and the Provincial Government of Camarines Sur. The dispute concerns the possession of Pitogo Island in Caramoan, Camarines Sur, comprising Lot Nos. 6972 and 6973. Lot No. 6973 is covered by Katibayan ng Orihinal na Titulo Blg. 35669 issued to the heirs of Mario Padayao, represented by Dante, with an area of 74,407 square meters. In January 2009, the Provincial Government declared Pitogo Island as a protected area and ordered residents to vacate. On February 4, 2009, armed men demolished structures on Pitogo Island. Dante filed a complaint seeking the recovery of possession and damages, asserting continuous, exclusive, and adverse possession since 1920, supported by tax payments, a historical survey plan, and a free patent application. The RTC ruled in favor of Dante, ordering the respo Case Digest (G.R. No. 260415) Expanded Legal Reasoning Model
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)