Case Digest (G.R. No. L-15214-15) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 170375 (filed January 16, 2006), the Republic of the Philippines, successor to the Iron and Steel Authority, sought to revive and prosecute an expropriation action against Maria Cristina Fertilizer Corporation (MCFC) for its occupation of a 30.25-hectare parcel in Iligan City. The Regional Trial Court (RTC), Branch 1, Iligan City, initially allowed substitution of the Republic for ISA but on July 12, 2005 dismissed the expropriation Complaint for failure to implead the true owner of the land and for alleged forum-shopping. Its October 24, 2005 Resolution denied reconsideration. In G.R. Nos. 178779 & 178894 (filed August 24 & September 6, 2007), Landtrade Realty Corporation, Teofilo Cacho, and Atty. Godofredo Cabildo appealed a January 19, 2007 Court of Appeals ruling that affirmed the RTC-Branch 3 Decision (July 17, 2004) quieting title in favor of Demetria Vidal and Azimuth International Development Corporation, excluding respondents Landtrade and Cacho from any o Case Digest (G.R. No. L-15214-15) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedent Land Registration Cases
- 1914 Cacho Case (Cacho v. U.S., 28 Phil. 616)
- Doña Demetria Cacho applied to register Lot 1 (0.36 ha) and Lot 2 (37.87 ha) in Iligan.
- LRC admitted only her conjugal home (Lot 1) and the southern cultivated portion of Lot 2; ordered deed and new survey.
- Supreme Court (1914) affirmed the LRC findings and reserved final decision until conditions were met.
- 1997 Cacho Case (Cacho v. Court of Appeals, 336 Phil. 154)
- Teofilo Cacho, claiming sole heirship, petitioned for re-issuance of lost Decrees Nos. 10364/18969.
- RTC granted petition; CA dismissed it; SC reinstated RTC, holding decrees ministerial acts and res judicata barred re-survey.
- Expropriation Case (G.R. No. 170375)
- In 1983 ISA/NSC filed Civil Case No. 106 against MCFC/PNB to expropriate occupancy rights over 32.25 ha in Iligan.
- SC (1995) ordered Republic substituted for ISA; RTC-Branch 1 (2005) dismissed for non-impleader of “owners” (Teofilo, Vidal, Landtrade, Azimuth) and forum shopping.
- Republic filed consolidated Petitions under R. 45/65 to set aside dismissals.
- Quieting of Title Case (G.R. Nos. 178779 & 178894)
- 1998 Vidal & Azimuth filed Civil Case No. 4452 to quiet title over Lot 1 & Lot 2 as sole heirs of Doña Demetria.
- Teofilo & Landtrade intervened, claiming heirship/transfers.
- RTC Branch 3 (2004) and CA (2007) ruled Vidal proved heirship; Teofilo/Landtrade had no valid interest.
- Landtrade, Teofilo, Cabildo filed R. 45 petitions to SC.
- Ejectment/Unlawful Detainer Case
- Landtrade sued NAPOCOR/TRANSCO in MTCC (2003, Case 11475-AF) for unlawful detainer of 27.03 ha; MTCC awarded possession, rent; defendants appealed to RTC Branch 5 (Case 6613).
- RTC 5 (Aug 2004) granted execution pending appeal for failure to post bond/deposit; Sheriff levied against NAPOCOR/TRANSCO.
- CA (Nov 2005) set aside execution, held utility exempt from bond/deposits; Landtrade filed R. 45 petition (G.R. 170505).
- Meanwhile, RTC 1 (Dec 2005) affirmed MTCC; NAPOCOR/TRANSCO filed R. 65 petitions to CA for injunction; CA (Jun 2006) granted Landtrade execution; SC TRO issued (Jul 2006).
- Cancellation of Titles & Reversion Case (G.R. No. 173401)
- Republic filed Civil Case No. 6686 (Oct 2004) to cancel OCT 0-1200/0-1201 (a.f.) in Doña Demetria’s name and revert lands, alleging certificates covered excess area beyond 1914 grant.
- Vidal/Azimuth moved to dismiss; RTC-Branch 4 (Dec 2005, May 2006) dismissed for lack of cause, res judicata, prescription, forum shopping.
- Republic filed R. 45 petition to SC.
Issues:
- Expropriation (G.R. 170375)
- Could RTC dismiss for non-joinder of “owners” (Teofilo, Vidal, Landtrade, Azimuth)?
- Did Republic commit forum shopping by also filing reversion case?
- Quieting of Title (G.R. 178779/178894)
- Did RTC/CA have jurisdiction to decide heirship in quieting action?
- Did Vidal state cause of action and prove heirship by admissible evidence?
- Was the action barred by prescription or laches?
- Ejectment/Unlawful Detainer (G.R. 170505; 173355-56; 173563-64)
- Was Landtrade entitled to execution pending appeal without bond/deposits?
- Could NAPOCOR/TRANSCO obtain preliminary injunction to stay execution of RTC decision?
- Reversion (G.R. 173401)
- Did Republic allege sufficient cause of action for cancellation & reversion of OCTs?
- Were reversion claims barred by res judicata (1914/1997 Cacho), prescription, or forum shopping?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)