Case Digest (G.R. No. 203610)
Facts:
Republic of the Philippines and Housing and Urban Development Coordinating Council (HUDCC) v. Gonzalo Roque, Jr., et al., G.R. No. 203610, October 10, 2016, Supreme Court Second Division, Brion, J., writing for the Court.The respondents — Gonzalo Roque, Jr., Manuela Almeda-Roque, Eduvigis A. Paredes, Michael A. Paredes, Purificacion Almeda, Jose A. Almeda, Michelle A. Almeda, Michael A. Almeda, Alberto Delura, and Theresa Almeda — owned several parcels totaling about 9,811 square meters in Constitution Hills, Quezon City. In 1978 the Republic, through the Department of Public Works and Highways (DPWH), negotiated purchases of portions of those lots at government-dictated prices markedly below market value for the National Government Center (NGC) Project; the respondents signed deeds of absolute sale. During negotiations, the government allegedly represented that (a) the NGC Project would raise the value of the owners’ remaining land and (b) in the event the project was abandoned the owners would have the right to repurchase the sold lots at the same price. The respondents continued to occupy parts of the property after sale; three titles were reissued in the Republic’s name and three remained in the respondents’ names.
After informal settlers occupied portions of the area and the NGC plan failed to materialize, the respondents sent letters in 1987, 1988 and 2004 seeking to repurchase; they received no definitive action. In 2003 Congress enacted R.A. No. 9207, reallocating parts of the NGC reservation for disposition as socialized housing, which the respondents say made clear the Republic had abandoned the NGC Project. In January 2005 the respondents filed in the Regional Trial Court (RTC) a complaint for annulment of sale on grounds of fraud, force, intimidation or undue influence, sought reconveyance (or the right to repurchase) and alternatively additional compensation.
The RTC rendered judgment for the respondents: it held the Republic was not immune from suit, that prescription and laches did not bar the action, and annulled the deeds of sale for fraud, ordering return of the purchase price; it denied damages and attorney’s fees to the respondents and dismissed the Republic’s counterclaims. The Republic appealed to the Court of Appeals (CA), which in its July 4, 2012 decisi...(Subscriber-Only)
Issues:
- Is the Republic immune from suit in this action?
- Is the respondents’ action annulment of sale barred by prescription or laches?
- May the respondents admit parol evidence (oral testimony) to establish alleged oral conditions of sale not reflected in the deeds (i.e., does an exception to the paro...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)