G.R. No. 240895 - Republic vs. Rallos

The case involves a 439-square-meter parcel of land in Cebu City designated as Lot No. 7245, which forms part of the V. Rama Avenue (formerly Guadalupe Road).
Title History:

Originally registered under Original Certificate of Title (OCT) No. RO-3105 (O-1930) issued on January 31, 1919 in the names of Victoria, Juan, and Numeriana Rallos.
Following judicial reconstitution (June 19, 1996), the OCT was cancelled on June 16, 1997, and a new title, Transfer Certificate of Title (TCT) No. 145498, was issued in the names of Romeo, William, Mateo, Lucia, Catherine, Rochelle, Christine Rallos and Januario V. Seno.

Private respondent Romeo filed the complaint asserting that he and the other Ralloses were successors-in-interest of Numeriana Rallos based on her alleged last will and testament dated April 13, 1945.
The complaint sought either the restoration of possession of Lot No. 7245 or its valuation with damages and attorney’s fees, noting a disputed familial relationship and inconsistencies in the testamentary document.

The Department of Public Works and Highways (DPWH), representing the Republic, initiated proceedings seeking the reversion of Lot No. 7245 to the public domain, arguing that the property forms part of a national road (V. Rama Avenue) beyond the commerce of man.
The government contended that the titling was irregular since Numeriana had died in 1941—four years before the alleged execution of her will—and that the subsequent reconstitution and issuance of TCT No. 145498 improperly conferred private dominion over public land.

The Regional Trial Court (RTC) rendered a Joint Judgment on October 30, 2009, dismissing both complaints for failure to substantiate:

The proper familial or heirship relationship of the private respondents claim; and
For the government, a sufficient basis to invoke reversion, citing a lack of proof of fraud in titling.

The RTC’s order was later consolidated and reaffirmed by a Joint Order (March 20, 2010) denying motions for reconsideration and appeals by both parties.
The Court of Appeals (CA), in its December 14, 2017 Decision, dismissed the DPWH’s appeal while partly granting Romeo’s appeal by remanding the case for the determination of just compensation for the taking of the property through an expropriation‑like scenario.

Private respondents relied on the submission of TCT No. 145498 and evidence of a last will and testament allegedly executed by Numeriana Rallos, which purportedly bequeathed the property to Francisco Rallos.
Testimony and documentary evidence, including the project of partition of Numeriana’s estate, revealed inconsistencies:

Conflicting accounts regarding Numeriana’s status (being single and childless versus indicated familial ties).
Indications that Francisco Rallos had sold the property in 1948, casting doubt on the subsequent acquisition of title by the Rallos family in 1997.

The government argued the property’s longstanding inclusion in the public road system, asserting that its acquisition by private individuals was irregular and contrary to public dominion principles.

Whether or not the private respondents have a valid ownership claim over Lot No. 7245 given the inconsistencies and lack of sufficient evidence regarding their alleged succession-in-interest from Numeriana Rallos.
Whether the reconstituted Original Certificate of Title (OCT) No. RO-3105 (O-1930) and all its derivative certificates, particularly TCT No. 145498, should be cancelled because the subject property forms part of a national road and belongs instead to the public dominion as argued by the Republic.