Case Digest (G.R. No. 183141)
Facts:
In Province of Cebu v. Heirs of Rufina Morales, G.R. No. 170115, decided on February 19, 2008, the petition arose from an action for specific performance and reconveyance filed by the surviving heirs of Rufina Morales (respondents Felomina V. Panopio, Nenita Villanueva, Erlinda V. Adriano, and Catalina V. Quesada) against the Province of Cebu. On September 27, 1961, the Province leased a 210-sqm portion of Lot No. 646-A to Morales. In 1964 the Province donated Lot 646-A to the City of Cebu, which subdivided it and issued TCT No. 30883 for Lot 646-A-3, the parcel occupied by Morales. On July 19, 1965, the City auctioned the donated lots to fund infrastructure projects; Morales, as occupant, matched the highest bid, paid the required deposit and downpayment but could not complete the balance. Meanwhile, the Province sued the City for reversion in Civil Case No. 238-BC, resulting in a 1974 compromise that returned unsold lots, including Lot 646-A-3, to the Province under TCT No. 10Case Digest (G.R. No. 183141)
Facts:
- Initial lease and donation
- On September 27, 1961, the Province of Cebu leased a 210-sqm portion of Lot No. 646-A (Banilad Estate) to Rufina Morales.
- In 1964, the Province donated Lot No. 646-A to the City of Cebu, which subdivided it; the portion occupied by Morales became Lot No. 646-A-3 (TCT No. 30883).
- Public auction and sale
- On July 19, 1965, the City auctioned Lot No. 646-A-3; Hever Bascon was the highest bidder.
- As the actual occupant-lessee, Morales exercised her preferential right by matching the highest bid and paid the required deposit and downpayment.
- Reversion of donation dispute
- The Province filed Civil Case No. 238-BC for reversion of donation against the City.
- On May 7, 1974, the parties compromised; approved July 17, 1974, returning donated lots—including Lot No. 646-A-3—to the Province (now TCT No. 104310).
- Morales died on February 20, 1969, before completing payments; she had paid only the deposit and downpayment.
- Heirs’ demands and litigation
- In 1983 and 1986, Catalina V. Quesada (niece) wrote to successive governors requesting formal conveyance; requests were ignored.
- Heirs (Panopio, Villanueva, Adriano, Quesada) filed Civil Case No. CEB-11140 in the RTC Cebu City for specific performance and reconveyance, consigned ₱13,450 as balance.
- They alleged a valid sale contract between the City and Morales, inadvertent reversion under the compromise, and confusion in payment due to a preliminary injunction.
Issues:
- Whether the sale by public auction to Morales was perfected and binding on the Province as successor-in-interest.
- Whether the absence of a formal deed and nonpayment of the balance invalidated the sale.
- Whether laches or prescription barred the heirs’ action for specific performance.
- Whether the consignation of the balance extinguished respondents’ obligation and entitled them to reconveyance.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)